Harvey M. Pert, Transferee - Page 25

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          transfer.  Fla. Stat. Ann. sec. 726.106(1) (West 1988).  Second,            
          a conveyance is also per se fraudulent if:  (a) The creditor's              
          claim arose before the transfer was made; (b) the transfer was              
          made to an insider for an antecedent debt; (c) the debtor was               
          insolvent at that time; and (d) the insider had reasonable cause            
          to believe that the debtor was insolvent.  Fla. Stat. Ann. sec.             
          726.106(2) (West 1988).                                                     
          B.   Whether Mrs. Pert Is Liable as a Transferee of Mr. Riffe's             
               Assets                                                                 
               1.   Contentions of the Parties                                        
               Respondent contends that Mrs. Pert is liable as a transferee           
          for Mr. Riffe's unpaid tax and additions to tax for 1986, 1987,             
          1988, and 1989, and contends that the transfer of Mr. Riffe's               
          assets to Mrs. Pert was both actually and per se fraudulent.                
               As discussed next, we conclude that respondent has                     
          established that the conveyances from Mr. Riffe's estate to Mrs.            
          Pert were per se fraudulent under Florida law.                              
               2.   Per Se Fraudulent Conveyances Under Florida Law                   
                    a.   Transfer of Assets of Mr. Riffe's Estate to Mrs.             
                         Pert                                                         
               Petitioners contend that respondent has not shown that the             
          assets which respondent contends were transferred from Mr.                  
          Riffe's estate to Mrs. Pert belonged solely to Mr. Riffe.  We               
          disagree.                                                                   







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