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I. Mrs. Pert's Bankruptcy
On December 22, 1993, Mrs. Pert filed a voluntary petition
for relief from creditors under chapter 7 of the U.S. Bankruptcy
Code, listing respondent as the primary creditor. In her
petition, Mrs. Pert listed as assets a joint interest in Sandy
Hook Road worth $130,000, $12 cash on hand, $57 in a joint
checking account, household goods and furnishings worth $3,108,
and other items including clothes, jewelry, and firearms worth
$530.
J. Closing Agreements and Notices of Transferee Liability
On April 23, 1993, Mrs. Pert signed closing agreements for
1986, 1988, and 1989 for herself and as personal representative
of Mr. Riffe's estate. See Pert v. Commissioner, 105 T.C. 370,
373 (1995). On June 4, 1993, this Court entered a stipulated
settlement agreement in Riffe v. Commissioner, docket No. 15214-
91, for 1987. Id.
On May 27, 1994, respondent issued notices of transferee
liability to Mr. and Mrs. Pert determining that each petitioner
was liable as a transferee of Mr. Riffe's assets.
OPINION
We must decide whether, and if so to what extent, Mrs. Pert
is liable as a transferee of Mr. Riffe's assets, and whether, and
if so to what extent, Mr. Pert is liable as a transferee of Mr.
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