How have courts interpreted the meaning of Section 548(a)(1) of the Bankruptcy Code?

¹¹ Courts construing the nearly identical language of 548(a)(1) of the Bankruptcy Code reach the same conclusion. See Brown v. Third Nat'l Bank (In re Sherman) , 67 F.3d 1348, 1355 n.6 (8th Cir. 1995) ("The [transferees] also argue that the transfers cannot be avoided as fraudulent because no creditor was harmed. However, the bankruptcy court correctly noted that under 548(a)(1), actual harm is not required; the trustee must show only that the debtor acted with the intent to hinder, delay or defraud creditors.").