- 44 - 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 totalPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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