Harvey M. Pert, Transferee - Page 4

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               3.  Whether Mr. Pert is liable as a successor transferee of            
          Mr. Riffe's assets for Mr. Riffe's unpaid income tax and                    
          additions to tax for 1986, 1987, 1988, and 1989.  We hold that he           
          is.                                                                         
               4.  Whether Mr. Pert is liable as a transferee of Mrs.                 
          Pert's assets for Mrs. Pert's unpaid income tax for 1986, 1987,             
          1988, and 1989.  We hold that he is.                                        
               5.  Whether respondent failed to prove the value of the                
          assets that Mrs. Pert transferred to Mr. Pert from Mr. Riffe's              
          estate, as petitioners contend; the value is $222,206, as                   
          respondent contends; or the value is some other amount.  We hold            
          that the value of assets transferred to Mr. Pert is $126,112.               
               6.  Whether respondent properly credited tax payments that             
          Mrs. Pert made on June 27 and December 11, 1991.  We hold that              
          respondent did.                                                             
               7.  Whether we should enter decision in Mrs. Pert's favor              
          because the U.S. Bankruptcy Court for the Middle District of                
          Florida discharged Mrs. Pert's liability as a transferee in a               
          previously filed bankruptcy.  We hold that we should not.                   
               Unless otherwise noted, section references are to the                  
          Internal Revenue Code of 1986 as in effect during the years in              
          issue.  Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              







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