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3. Property Passing Outside of Probate
Mrs. Pert was required to report the value of property
passing outside of probate, including jointly owned property, to
the Florida Department of Revenue (Preliminary Notice and
Report). On May 13, 1991, Mrs. Pert reported that Lot 28,
College Hill, which she valued at about $41,000, passed outside
of probate, and that the total value of all property in which Mr.
Riffe had an interest was $537,358.
On June 5, 1991, Elliott met with Mrs. Pert's tax attorney
to discuss adjustments Elliot had made to Mr. Riffe's and Mrs.
Pert's income for 1986, 1987, 1988, and 1989, and to give Mrs.
Pert's tax attorney a copy of Elliott's report detailing the
adjustments based on unreported income and including the addition
to tax for fraud.
Mrs. Pert married Mr. Pert on September 7, 1991, while she
was administering Mr. Riffe's estate. Mr. Pert had known Mr.
Riffe for many years.
Mrs. Pert, as representative of Mr. Riffe's estate, signed
documents under penalty of perjury on March 23, 1992 (petition to
extend time for filing final accounting and petition for
discharge), June 19, 1992 (petition to extend time for filing
final accounting and petition for discharge), and October 8, 1992
(statement regarding creditors with attachment showing debt owed
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