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We note that the parties analyze each type of asset and
liability separately. Also, respondent makes no assertion as to
the amount of any possible goodwill or related intangibles.
There follow our specific findings with regard to the assets and
liabilities the amounts of which are in dispute. We note
petitioner's failure, other than through self-serving testimony,
to offer on a timely basis any credible evidence as to the value
of most of the assets and liabilities involved in this case.
Accounts Receivable
We agree with respondent that the accounts receivable should
reflect an amount of $63,730. This amount represents the $40,660
amount for accounts receivable listed in the Internal Document,
the $42,675 accounts receivable billed by Hanna PC that relate to
legal services performed by Associates PC before the transfer
date, and a $19,605 reduction for uncollectible accounts
receivable.
Hanna PC argues that because Associates PC was a cash basis
taxpayer, none of Associates PC's accounts receivable should be
included in the calculation of the amount of the assets
transferred. Whether Associates PC was a cash or an accrual
basis taxpayer, however, has no bearing on the amount of the
assets transferred. See UFTA sec. 24.004(d).
Hanna PC also argues that the accounts receivable billed by
Hanna PC represent Hanna's personal property, that therefore the
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