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transfers occurred there. Commissioner v. Stern, supra; Fibel v.
Commissioner, 44 T.C. 647, 657 (1965).
2. Transferee Liability Under Florida Law
Under Florida law, a transferee may be held liable for the
debts of a transferor if the transferor conveys assets to the
transferee fraudulently or in a manner that is "per se"
fraudulent. Fla. Stat. Ann. secs. 726.105, 726.106 (West 1988);
Hagaman v. Commissioner, 100 T.C. 180, 184 (1993) (transferee
liability established by applying Florida fraudulent conveyance
law); Schad v. Commissioner, 87 T.C. 609, 614 (1986), affd.
without published opinion 827 F.2d 774 (11th Cir. 1987).
One way that a creditor may show that a conveyance is
fraudulent is by showing that the transferor actually intended to
defraud or hinder creditors. Fla. Stat. Ann. sec. 726.105(1)(a)
(West 1988)2; Florida Fruit Canners, Inc. v. Walker, 90 F.2d 753,
2Fla. Stat. Ann. sec. 726.105 (West 1988) provides:
726.105. Transfers fraudulent as to present and future
creditors.
(1) A transfer made or obligation incurred by a debtor
is fraudulent as to a creditor, whether the
creditor's claim arose before or after the
transfer was made or the obligation was incurred,
if the debtor made the transfer or incurred the
obligation:
(a) With actual intent to hinder, delay, or
defraud any creditor of the debtor; or
(b) Without receiving a reasonably equivalent
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