Smith v. Arthur Anderson LLP, 421 F.3d 989 (9th Cir. 2005)
    “We need not make any general pronouncements on the deepening insolvency theory, not least because it is difficult to grasp exactly what that theory entails. . . .We do, however, agree with the Third Circuit’s observation in Lafferty that ‘prolonging an insolvent corporation’s life through bad debt may’ dissipate corporate assets and thereby harm the value of corporate property. 267 F.3d 350.”