- 30 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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