James E. Griffin and Katrina F. Griffin, Transferees - Page 21

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               1.  Transfers Directly to Mr. Fisher                                   

               Except for the $40,016.22 previously allowed by respondent,            
          the only retransfer of property that petitioners made directly to           
          Mr. Fisher was the $2,500 check dated August 11, 1992.                      
          Respondent acted to collect from petitioners when the notice of             
          transferee liability was issued on July 7, 1994.   Because the              
          $2,500 payment occurred before July 7, 1994, we find that the               
          amount of transferee liability asserted by respondent should be             
          reduced to the extent of $2,500.18                                          

               2.  Transfers to Mr. Fisher's Creditors                                

               Petitioners contend that the remaining transfers of cash to            
          Ameritrust Co. National Association, Mr. Randolph, and Mr.                  
          Brown,19 and the transfer of the two parcels to the United States           

               18Respondent contends that petitioners and Mr. Fisher                  
          conspired to defraud Mr. Fisher's creditors.  In Gobins v.                  
          Commissioner, 18 T.C. 1159, 1174 (1952), affd. 217 F.2d 952 (9th            
          Cir. 1954), we noted that in certain cases it is possible that              
          retransfers "might be the result of collusion between the parties           
          and made in such manner that it also would be in fraud of                   
          creditors."  Despite the fact that Mr. Fisher and petitioners               
          were closely related, there is no evidence of collusion on the              
          part of petitioners with regard to the retransfer of $2,500 on              
          Aug. 11, 1992.                                                              
               19Petitioners do not identify the respective relationships             
          of these payees to Mr. Fisher or the purposes of these payments.            
          However, respondent identified the payees, Mr. Randolph and Mr.             
          Brown, as Mr. Fisher's attorneys.  Respondent also identified the           
          payee, Ameritrust Co. National Association, as a creditor of Mr.            
          Fisher; however, there is nothing in the record that would                  

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