Does making a transfer constitute an incurrence of an obligation?

There clearly is a difference between making a transfer and incurring an obligation; otherwise, the relevant statutory provisions would not have used both terms. See Rake v. Wade, 508 U.S. 464, 471, 113 S.Ct. 2187, 124 L.Ed.2d 424 (1993) (To avoid deny[ing] effect to a part of a statute, we accord significance and effect ... to every word.) (internal quotation and citations omitted). Relatedly, Bankruptcy Code section 101(54) broadly defines transfer to include each mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with(i) property; or (ii) an interest in property, 11 U.S.C. 101(54)(D) (as well as the creation of a lien, the retention of title as a security interest, and the foreclosure of a debtor's equity of redemption, 11 U.S.C. 101(54)(A)-(C)), but the definition does not include the incurrence of an obligation. A transfereven under the exceedingly broad Bankruptcy Code definitionis ultimately a disposition of property. If avoided, a transfer is preserved under Bankruptcy Code section 551 and recoverable under Bankruptcy Code section 550, while the avoidance of an obligation, which is not mentioned in Bankruptcy Code sections 550 and 551, instead reduces dollar for dollar the claims that the estate must pay; there is nothing to preserve or bring back.¹⁷ Similarly, section 502(d) of the Bankruptcy Code provides for the disallowance of any claim of an entity from which property is recoverable under section 550 or that is a transferee of an avoidable transfer, regardless whether the claim is related to the transfer, but is silent as to the disallowance of any claim of the obligee of an avoided obligation.¹⁸