In this Morgan Lewis case summary of Rajala v Spender Fane LLP, et al., (In re Generation Res. Holding Co., LLC), No. 19-3226, 2020 WL 3887850 (10th Cir. July 10, 2020), the bankruptcy trustee sought to recover litigation proceeds pursuant to Section 550 of the US Bankruptcy Code, which permits the recovery of property transferred from initial and subsequent transferees. In denying recovery, the Tenth Circuit held that Congress did not intend for a bankruptcy trustee to trace proceeds derived from property against any person who received such proceeds as payment for goods and services.