James E. Griffin and Katrina F. Griffin, Transferees - Page 18

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          B.  Transfers of Cash                                                       

               In addition to the fraudulent transfer of real property and            
          the payments Mr. Fisher made on the loan, respondent contends               
          that the $14,457.97 retained by petitioners in the circular                 
          movement of money for Mr. Fisher also was a fraudulent transfer.            
          Petitioners failed to provide any substantive argument as to why            
          this transfer was not fraudulent.  However, in their answering              
          brief, petitioners, for the first time, contend that respondent's           
          focus on Florida law regarding their liability for these                    
          transfers may be misplaced.                                                 
               Petitioners suggest that Arizona law might apply because               
          they resided in the State of Arizona when the transfers of cash             
          took place.  Arizona, like Florida, adopted the Uniform                     
          Fraudulent Transfer Act, which was effective during the years in            
          issue.  See Ariz. Rev. Stat. Ann. secs. 44-1001 to 44-1010 (West            
          1994).  Petitioners have not demonstrated any difference between            
          Arizona's version of the Uniform Fraudulent Transfer Act and                
          Florida's version of the same act.  Further, our review of these            
          two statutes reveals no significant differences in their language           
          as applicable to the facts of this case.  Therefore, our                    
          determination of petitioners' transferee liability regarding the            
          receipt of cash would be the same under either State's law.                 
               As with the transfers of the real property and the payment             
          of the loan, there are several factors present in the transfer of           





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