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3. Whether Mr. Pert is liable as a successor transferee of
Mr. Riffe's assets for Mr. Riffe's unpaid income tax and
additions to tax for 1986, 1987, 1988, and 1989. We hold that he
is.
4. Whether Mr. Pert is liable as a transferee of Mrs.
Pert's assets for Mrs. Pert's unpaid income tax for 1986, 1987,
1988, and 1989. We hold that he is.
5. Whether respondent failed to prove the value of the
assets that Mrs. Pert transferred to Mr. Pert from Mr. Riffe's
estate, as petitioners contend; the value is $222,206, as
respondent contends; or the value is some other amount. We hold
that the value of assets transferred to Mr. Pert is $126,112.
6. Whether respondent properly credited tax payments that
Mrs. Pert made on June 27 and December 11, 1991. We hold that
respondent did.
7. Whether we should enter decision in Mrs. Pert's favor
because the U.S. Bankruptcy Court for the Middle District of
Florida discharged Mrs. Pert's liability as a transferee in a
previously filed bankruptcy. We hold that we should not.
Unless otherwise noted, section references are to the
Internal Revenue Code of 1986 as in effect during the years in
issue. Rule references are to the Tax Court Rules of Practice
and Procedure.
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