Harvey M. Pert, Transferee - Page 34

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          married, and later combined their businesses to form Perticular             
          Lawn, Inc.                                                                  
               3.   Conclusion                                                        
               We conclude that respondent has shown that the transfers of            
          the assets in the inventory were per se fraudulent under Fla.               
          Stat. Ann. section 726.106(1) (West 1988).                                  
               4.   Value of the Property Transferred                                 
               Respondent contends that Mr. Riffe's estate included                   
          $113,600 of property other than cash.  Petitioners contend that             
          respondent has not established the fair market value of the non-            
          cash property listed in the inventory that Mrs. Pert filed with             
          the probate court, and contend that the values given in the                 
          inventory are not evidence of fair market value.  We agree with             
          respondent.                                                                 
               Under Florida law, the personal representative of an estate            
          must file an inventory of the property of the estate, including             
          the estimated fair market value of each asset when decedent died.           
          Fla. Stat. Ann. sec. 733.604(1) (West 1988).  Kaltenbach                    
          testified that the values used in the inventory were based on the           
          best information available at the time without the expense of               
          appraisals.  We do not believe that the absence of appraisals or            
          the fact that Mr. Riffe’s estate was larger than $60,000 and                
          smaller than $600,000 makes the estimate in the inventory                   
          unreliable.                                                                 





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