- 22 -
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.
19(...continued)
indicate whether this creditor (or any other creditor) had
priority over respondent.
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