In In re Circle Land and Cattle Corp., 213 B.R. 870 (Bankr. D. Kan. 1997), the bankruptcy court considered the application of a substantive consolidation claim to pull the assets of an alleged corporate alter ego into the bankruptcy estate. The Circle Land court recognized the substantive consolidation doctrine but declined to apply such doctrine under the circumstances presented there. The Circle Land decision suggests that substantive consolidation is rarely proper unless the party seeking the consolidation can demonstrate that no creditor will be harmed by the consolidation. 213 B.R. at 875-76.