The U.S. Supreme Court case Holt, Trustee in Bankruptcy of Davis, Kelly & Co., v. Crucible Steel Company of America (1911) revolved around the issue of whether a trustee in bankruptcy could recover payments made by an insolvent debtor within four months prior to filing for bankruptcy under Section 60b and Section 67e of the Bankruptcy Act. The defendant, Crucible Steel Company had received payment from Davis, Kelly & Co., who later filed for bankruptcy. The plaintiff argued that these payments were preferential transfers as they allowed the steel company to receive more than it would have during liquidation proceedings under federal law. However, the court ruled in favor of Crucible Steel Company stating that there was no evidence showing that at the time when those payments were made either party believed insolvency was imminent or intended any preference; hence such transactions did not fall within provisions meant to prevent fraudulent conveyances or preferences over other creditors.

In the dissenting opinion for Holt, Trustee in Bankruptcy of Davis, Kelly & Co., v. Crucible Steel Company of America, it was argued that the majority's decision contradicted established principles regarding bankruptcy law and commercial transactions. The dissenting justices believed that a debtor should not be allowed to prefer one creditor over another by transferring assets before declaring bankruptcy. They contended that such actions undermine the equitable distribution of assets among all creditors - a fundamental principle in bankruptcy proceedings. Furthermore, they disagreed with the majority's interpretation of "fraudulent intent," arguing instead that any act deliberately favoring one creditor at others' expense should be considered fraudulent under bankruptcy laws regardless if there is no actual intent to defraud other creditors.