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transfer. Fla. Stat. Ann. sec. 726.106(1) (West 1988). Second,
a conveyance is also per se fraudulent if: (a) The creditor's
claim arose before the transfer was made; (b) the transfer was
made to an insider for an antecedent debt; (c) the debtor was
insolvent at that time; and (d) the insider had reasonable cause
to believe that the debtor was insolvent. Fla. Stat. Ann. sec.
726.106(2) (West 1988).
B. Whether Mrs. Pert Is Liable as a Transferee of Mr. Riffe's
Assets
1. Contentions of the Parties
Respondent contends that Mrs. Pert is liable as a transferee
for Mr. Riffe's unpaid tax and additions to tax for 1986, 1987,
1988, and 1989, and contends that the transfer of Mr. Riffe's
assets to Mrs. Pert was both actually and per se fraudulent.
As discussed next, we conclude that respondent has
established that the conveyances from Mr. Riffe's estate to Mrs.
Pert were per se fraudulent under Florida law.
2. Per Se Fraudulent Conveyances Under Florida Law
a. Transfer of Assets of Mr. Riffe's Estate to Mrs.
Pert
Petitioners contend that respondent has not shown that the
assets which respondent contends were transferred from Mr.
Riffe's estate to Mrs. Pert belonged solely to Mr. Riffe. We
disagree.
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