- 20 -                                         
          Babes' assets without consideration because they gave up their               
          stock in House of Babes.  We disagree.  After the liquidation,               
          the shareholders had House of Babes' assets, and House of Babes              
          was left with no ability to pay its debts.                                   
               Petitioners contend that, to show that House of Babes was               
          insolvent, respondent must show that the liabilities of House of             
          Babes exceeded its assets when petitioners exchanged their stock             
          for the liquidating distribution.  We disagree.  House of Babes              
          had no assets and no means of paying its debts after it was                  
          liquidated.  No further accounting is required.                              
                    d.   Transfer of Assets With Knowledge of Pending                  
                         Liability                                                     
               A transfer of assets with knowledge of a pending liability              
          is a badge of fraud.  Cleveland Trust Co. v. Foster, supra at                
          114.  Waldorf knew that House of Babes was liable for Federal                
          corporate income tax when he sold its assets and it was                      
          liquidated.  Wiltzius knew, or should have known, that House of              
          Babes had a corporate tax liability when it was liquidated                   
          because he knew that the shareholders were skimming a large                  
          amount of gross receipts from House of Babes.                                
                    e.   Insolvency and Substantial Indebtedness                       
               Under Florida law, a conveyance is more likely to be                    
          fraudulent if it made the debtor insolvent or if the transferor              
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