value” “in exchange for” their contributions to the church. DECISION OF THE BANKRUPTCY COURT The bankruptcy court granted the trustee’s motion for summary judgment and denied the church’s motion. The bankruptcy court held that the debtors’ contributions to the church were avoidable transfers under § 548(a)(2)(A) because the debtors did not receive “reasonably equivalent value” “in exchange for” their contributions. 148 B.R. at 890-93. The bankruptcy court concluded that “value” referred solely to economic value, that is, “property” in a physical or material sense, and that religious services, theological programs and access to the church’s facilities did not meet this economic defini tion of value. Id. at 891, 895-96 (rejecting In re Moses, 59 B.R. 815, 818 (Bankr.N.D.Ga. 1986) (Moses) (<HOLDING>), and In re Missionary Baptist Foundation of
holding that denial of tax exemption for part of church property that was not necessary for occupancy and enjoyment of church did not violate first amendment holding church services constitute property within meaning of  548 holding that requiring church to make contributions to workers compensation fund opposed by such church did not violate first amendment holding that tax exemption for church property does not violate establishment clause holding that a state is not a person within the meaning of  1983