- 18 -
We disagree. Kagen testified that the buyers received a letter
from the IRS directing that a check be paid directly to the IRS
on Godby's account. This does not show that House of Babes had
assets.
Petitioners contend that under Fla. Stat. Ann. sec. 607.1405
(West 1993), House of Babes kept title to the note after Florida
dissolved the corporation in 1987. We disagree. That section
became effective July 1, 1990. 1989 Fla. Laws ch. 89-154, sec.
125.
b. The Existence of a Close Relationship Between
Transferor and Transferee
A conveyance is more likely to be fraudulent if there is a
close relationship between the transferor and transferee. Scott
v. Dansby, supra at 333; see Hagaman v. Commissioner, supra;
Schad v. Commissioner, supra. There was a close relationship
between House of Babes and petitioners. Petitioners owned and
controlled House of Babes. Waldorf was a 32.5-percent
shareholder and president, and Wiltzius was a 22.5-percent
shareholder and signed documents as secretary for House of Babes.
Petitioners contend that respondent must prove that Wiltzius
is an insider under Fla. Stat. Ann. sec. 726.106(2) (West 1988)
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