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MSSTA realized from the sale of its assets to AST (i.e., a 10.5-
percent stock interest in AST and $9,508 in cash) was made by
MSSTA, the transferor, to Mr. Scott, the transferee, with the
intent to hinder, delay, or defraud the Service within the mean-
ing of the Colorado fraudulent conveyance statute.19 We further
find that Mr. Scott is liable as a transferee of property of
MSSTA for MSSTA's unpaid tax liability to the extent of $104,580.
We shall now address respondent's position regarding Ms.
Scott. In support of respondent's contention that Ms. Scott, as
a transferee of property of MSSTA, is liable under the Colorado
fraudulent conveyance statute for MSSTA's unpaid tax liability to
the extent of $95,072, respondent asserts:
Mrs. Scott could not even recite what kind of consid-
eration she paid for the AST stock that constitutes the
property she received from MSSTA. She asked no ques-
tions at all during the closing of the transactions.
Moreover, to the extent that she stands as a nominee of
Mr. Scott, his conduct should be imputed to her.
Regardless of her head-in-the-sand approach, Mrs.
Scott's receipt of MSSTA's assets [was] part of a series of
transactions that left MSSTA insolvent. This badge of
fraud, along with the indifference to the transactions,
support a finding of liability as to Mrs. Scott * * *.
On the instant record, we find that respondent has failed to
establish that Ms. Scott knew of, or participated in, the intent
of MSSTA to hinder, delay, or defraud the Service of MSSTA's un-
paid tax liability within the meaning of the Colorado fraudulent
conveyance statute. At some undisclosed time prior to September
19 We have considered all of the arguments of petitioners that
are not addressed herein, and we find them to be without merit.
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