Mark J. Hanna, P.C., Transferee - Page 11




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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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