Harvey M. Pert, Transferee - Page 44

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          1993 that, if respondent was successful with the proposed                   
          assessments of tax and additions to tax, Mrs. Pert would never              
          have to pay them because she would file for bankruptcy                      
          protection.  We conclude that the transfers left Mr. Riffe's                
          estate and Mrs. Pert insolvent.                                             
                    j.   Whether Mr. Riffe's Estate or Mrs. Pert                      
                         Transferred Property Shortly Before or After                 
                         Incurring Substantial Debt                                   
               Mrs. Pert incurred a substantial tax debt to respondent when           
          she signed the joint returns at issue here, the last of which was           
          due April 15, 1990.  Elliott interviewed her on February 28,                
          1991.  She began transferring assets on March 19, 1991, when she            
          wrote a $5,000 check to herself from Peoples State Bank account.            
          We conclude that she knew that she and Mr. Riffe’s estate owed              
          tax and that she transferred the property shortly thereafter.               
                    k.   Transfer to a Lienor                                         
               There is no evidence that Mrs. Pert transferred assets to a            
          lienor who transferred them to an insider.  This badge does not             
          help respondent.                                                            
                    l.   Conclusion                                                   
               We conclude that respondent has shown that Mrs. Pert had               
          actual intent to hinder, delay, or defraud respondent.                      
               5.  Value of the Property Transferred to Mr. Pert                      
               We conclude that Mrs. Pert transferred to Mr. Pert $100,000            
          in cash, a 1992 Ford Explorer and the 1987 GMC truck.  The total            





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