Richard Bowman v. El Paso CGP Company, L.L.C., 431 S.W.3d 781

El Paso CGP Company, L.L.C. sued Richard Bowman for fraudulent transfers by Atasca Resources, Inc. to Bowman.
The trial court granted El Paso a final summary judgment for $987,915.82.
TUFTA § 24.006(a) requires showing no genuine fact issue and lack of reasonably equivalent value.
El Paso relied on Bowman's statements and a discovery document detailing payments between Atasca and Bowman.
Bowman admitted the transfers were loans/loan repayments, with no promissory notes or formal terms, and claimed he repaid more than he borrowed.
The appellate court reversed, concluding a genuine issue of material fact exists as to reasonably equivalent value and remanded for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable equivalent value?	Bowman received no value from Atasca	Transfers were loans with repayment; value present	Issue sustained; material fact exists as to value and remand for trial
Were transfers to Bowman loans?	Evidence shows loans from Atasca to Bowman	Promissory terms unspecified; not conclusively non-loans	Not conclusively non-loans; factual dispute remains
Did Atasca receive value where Bowman repaid more to Atasca than received?	El Paso contends insufficient value	Bowman testified net transfers favored Atasca; value present	Issue sustains factual dispute; remand for fact-finder to determine value.

T.O. Stanley Boot Co. v. Bank of El Paso, 847 S.W.2d 218 (Tex. 1992) (loan agreement terms often required for enforceability; definiteness matters)
In re Hinsley, 201 F.3d 638 (5th Cir. 2000) (value analysis under bankruptcy and fraudulent transfer rules)
In re Mladenka, 130 S.W.3d 397 (Tex. App.—Houston [14th Dist.] 2004) (burden to prove fraudulent transfer; value considerations)
In re Erlewine, 349 F.3d 205 (5th Cir. 2003) (reasonableness of value often fact-intensive)
In re Food & Fibre Protection, Ltd., 168 B.R. 408 (Bankr. D. Ariz. 1994) (subsistence of value where debtor transferred more than received)