Harvey M. Pert, Transferee - Page 11

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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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