Thomas H. Scott and Lynn D. Scott, Transferees - Page 46

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               Respondent contends that, as a transferee of property of               
          MSSTA, each petitioner is liable under Colorado law for MSSTA's             
          unpaid tax liability to the extent of the assets that MSSTA                 
          transferred to each of them, viz., $104,580 to Mr. Scott and                
          $95,072 to Ms. Scott.  In support of that contention with respect           
          to Mr. Scott, respondent relies on (1) Colo. Rev. Stat. sec. 7-5-           
          114(1)(c) (repl. vol. 1986) (repealed 1994) (Colorado liquidation           
          statute), (2) Colo. Rev. Stat. sec. 7-5-114(1)(b) (repl. vol.               
          1986) (repealed 1994) (Colorado redemption statute), and/or                 
          (3) Colo. Rev. Stat. sec. 38-10-117 (repl. vol. 1982) (Colorado             
          fraudulent conveyance statute).  In support of respondent's con-            
          tention with respect to Ms. Scott, respondent relies only on the            
          Colorado fraudulent conveyance statute.  Petitioners counter that           
          neither of them is liable under the Colorado statutes on which              
          respondent relies.                                                          
               We shall turn first to the Colorado fraudulent conveyance              
          statute on which respondent relies because that statute disposes            
          of the transferee liability questions remaining in this case.               
          The Colorado fraudulent conveyance statute provides:                        
                    Every conveyance or assignment in writing or                      
               otherwise of any estate or interest in lands, goods, or                
               things in action or of any rents and profits issuing                   
               thereupon, and every charge upon lands, goods, or                      
               things in action or upon the rents and profits thereof                 
               made with the intent to hinder, delay, or defraud                      
               creditors or other persons of their lawful suits,                      
               damages, forfeitures, debts, or demands, and every bond                
               or other evidence of debt given, suits commenced, or                   
               decree or judgment suffered with the like intent as                    




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