Robert John Kayian, Transferee - Page 30

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          Watson Realty Corp. v. Quinn, 452 So. 2d 568 (Fla. 1984) (per               
               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                     
               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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