Harvey M. Pert, Transferee - Page 35

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               Mr. Riffe's estate included $383,358 in cash.                          
               We conclude that respondent has established that the value             
          of assets transferred from Mr. Riffe's estate to Mrs. Pert was              
          $399,535.                                                                   
               5.   Conclusion                                                        
               We conclude that respondent has established that Mrs. Pert             
          is liable up to $399,535 as a transferee of Mr. Riffe's assets.             
          C.   Whether Mr. Pert Is Liable as a Transferee of Mrs. Pert's              
               Assets or as a Successor Transferee of Assets From Mr.                 
               Riffe's Estate                                                         
               1.   Contentions of the Parties                                        
               Respondent contends that Mr. Pert is liable as a transferee            
          of the assets of Mrs. Pert, and as a successor transferee of the            
          assets of Mr. Riffe's estate, under Fla. Stat. Ann. secs.                   
          726.101(a) (transfer defined) and 726.106 (West 1988) (per se               
          fraudulent conveyance) and Fla. Stat. Ann. sec. 726.105(1)(a)               
          (West 1988) (actual or constructive fraud).  Respondent contends            
          that Mrs. Pert transferred assets which had a total value of                
          $222,206 from Mr. Riffe's estate to Mr. Pert when Mr. Riffe's tax           
          debt, additions to tax, and interest were unpaid and before Mrs.            
          Pert filed a voluntary bankruptcy petition under chapter 7 of the           
          U.S. Bankruptcy Code.                                                       
               Petitioners contend that respondent failed to prove that Mr.           
          Pert is liable as a transferee or successor transferee.                     
          Petitioners contend that Mrs. Pert spent any money she received             





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