James E. Griffin and Katrina F. Griffin, Transferees - Page 22

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          were made in Mr. Fisher's behalf.  However, petitioners do not              
          offer any proof or make any argument to show that the debts and             
          fees paid on Mr. Fisher's behalf or that the transfer of the two            
          parcels of land in accordance with Mr. Fisher's plea agreement              
          had priority over his indebtedness to respondent.  Transferee               
          liability having been established, it is incumbent upon                     
          petitioners to make such a showing.  Gobins v. Commissioner, 18             
          T.C. 1159, 1174 (1952), affd. 217 F.2d 952 (9th Cir. 1954).                 
          Accordingly, petitioners' claim that they are relieved of                   
          liability by reason of the expenditures made by them on Mr.                 
          Fisher's behalf is rejected.                                                
               To the extent petitioners have raised other issues or                  
          arguments, we have fully examined them and find them to be                  
          without merit.  Summarizing our conclusions, then, we hold that             
          petitioners are liable as transferees for Mr. Fisher's income tax           
          deficiencies and additions to tax for 1991 and 1992 to the extent           
          of $85,016 ($87,516, as determined by respondent, less the $2,500           
          retransferred to Mr. Fisher), plus interest on such amount as               
          provided below.                                                             

          indicate whether this creditor (or any other creditor) had                  
          priority over respondent.                                                   

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