was made.” 15. The “new value” provided by Crofton in the form of loans or advances need not have remained unpaid in order to offset previous transfers. E & C has not argued to the contrary, but the Court nonetheless highlights the point in order to make clear why it is not necessary to determine whether Crofton later received repayment or reimbursement for any “new value.” Several courts have suggested that, under the Bankruptcy Code, the “new value” defense does not require that the “new value” remain unpaid. Cf. In re IRFM, Inc., 52 F.3d 228, 231-32 (9th Cir.1995) (discussing various approaches to determining whether “new value” for which the debtor later pays can offset prior preferential transfers under 11 U.S.C. § 547); In re Jones Truck Lines, 130 F.3d 323, 329 (8th Cir.1997) (<HOLDING>); In re Chez Foley, Inc., 211 B.R. 25, 27-29
holding determination of property value in case to decide if assessed value was excessive is not a liquidated demand where only evidence of property value was the conclusory allegation of value in plaintiffs unsworn petition holding that under 11 usc  547c4 a later payment in exchange for new value only deprives the defendant of the new value defense if the later payment is an otherwise unavoidable transfer holding bankruptcy courts determination that payment on account was made for new value erroneous as matter of law holding new value exception exists holding that new value exception still exists