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Watson Realty Corp. v. Quinn, 452 So. 2d 568 (Fla. 1984) (per
curiam).
Petitioners maintain that Mr. Kayian, Jr. is the initial
transferee of certain assets of Mr. Kayian, Sr. and that they
received certain of those assets from Mr. Kayian, Jr. Petition-
ers further maintain that "if Petitioners are liable for any
portion of * * * [Mr. Kayian, Sr.'s 1987-1989] unpaid income tax
liabilities, it is as transferees of a transferee [Mr. Kayian,
Jr.]." According to petitioners,
It is the initial transfer, from Transferor [Mr.
Kayian, Sr.] to Harry Kayian, Jr., that must be ex-
amined to determine whether Harry Kayian, Jr. was a
transferee "at law or in equity". If he was a trans-
feree at law or in equity, then Petitioners may be held
liable, as transferees of a transferee, to the extent
of the assets of * * * [Mr. Kayian, Sr.] that they
received.
Respondent argues that whether petitioners received the
transferred properties as transferees of a transferor (Mr.
Kayian, Sr.) or as transferees of a transferee (Mr. Kayian, Jr.)
is irrelevant for purposes of determining their respective
liabilities in these cases. Respondent further contends
that the record in this case [sic] supports a finding
that Harry Kayian, Jr., while himself a transferee, was
a conduit complying with his father's direct instruc-
tions that he was transferring his property to his
children and grandchildren via his son present at the
time, Harry Kayian, Jr., who was also the eldest child.
* * * Accordingly, the record supports a finding that
each recipient of the transferred property was a direct
transferee of the transferor Harry Kayian, Sr., rather
than a transferee of a transferee, Harry Kayian, Jr.
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