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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 vol. 1986) (repealed 1994) (Colorado liquidation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1986) (repealed 1994) (Colorado redemption statute), and/or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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