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value of the property that Mrs. Pert transferred to Mr. Pert is
$126,112.
D. Whether Mr. Pert is Liable as a Transferee of Mrs. Pert's
Assets
Respondent contends that Mr. Pert is liable as a transferee
of Mrs. Pert's assets for her income tax deficiencies for 1986,
1987, 1988, and 1989, totaling $67,672 plus interest.
Petitioners contend that respondent failed to show that Mr.
Pert is liable as a transferee of the assets of Mrs. Pert for the
same reasons discussed above at par. C. In addition to the
arguments in par. C, above, petitioners contend that respondent
failed to show that collection efforts against Mrs. Pert would be
fruitless. We disagree. Fla. Stat. Ann. section 726.105 (West
1988) does not require the creditor to prove that collection
efforts would be fruitless. In any event, we conclude that
collection efforts against Mrs. Pert would have been fruitless
because she had no assets and filed for protection in bankruptcy.
We conclude that Mr. Pert is liable as a transferee of Mrs.
Pert's assets for her income tax deficiencies for 1986, 1987,
1988, and 1989, and that she transferred assets to Mr. Pert worth
$126,112. Mrs. Pert's income tax liability for those years is
$67,672 plus interest.
E. Whether Respondent Properly Credited Mrs. Pert's Payments
Petitioners contend that the amounts of unpaid tax stated in
the notices of transferee liability are incorrect because
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