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from Mr. Riffe's estate, that Mr. Pert's increased financial
resources came from gifts from his parents, and that Mr. Pert
received no financial benefits from Mrs. Pert.
2. Background
The principles used to decide if a transferee is liable are
also used in deciding if a successor transferee (i.e., transferee
of a transferee) is liable. Bos Lines, Inc. v. Commissioner, 354
F.2d 830, 834-835 (8th Cir. 1965), affg. T.C. Memo. 1965-71; Pert
v. Commissioner, 105 T.C. at 377. Thus, to show that Mr. Pert is
liable as a successor transferee, respondent must establish that
Mrs. Pert fraudulently conveyed assets from Mr. Riffe's estate to
Mr. Pert under Fla. Stat. Ann. sections 726.105(1)(a) or (b)
(West 1988), or that there was per se fraud under Fla. Stat. Ann.
sec. 726.106 (1) or (2) (West 1988). As discussed next, we
conclude that respondent has established that there were
conveyances from Mr. Riffe's estate through Mrs. Pert to Mr.
Pert, and that those conveyances were fraudulent under Fla. Stat.
Ann. section 726.105(1)(a) and (2) (West 1988).
3. Mrs. Pert's Transfer of Assets From Mr. Riffe's Estate
to Mr. Pert
Respondent contends that Mrs. Pert transferred the following
assets from Mr. Riffe's estate to Mr. Pert: (a) $100,000 in
cash; (b) a $43,072 certificate of deposit; (c) $53,018, which
Mr. Pert used to buy the 610 Sandy Hook Road property; (d) a 1992
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