South Dakota Code § 47-26-23

Power of court in liquidation proceedings--Action by creditor
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Courts of equity shall have full power to liquidate the assets and affairs of a corporation in an action by a creditor:
(1) When the claim of the creditor has been reduced to judgment and an execution thereon has been returned unsatisfied and it is established that the corporation is insolvent; or
(2) When the corporation has admitted in writing that the claim of the creditor is due and owing and it is established that the corporation is insolvent.

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