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On the record before us, we agree with respondent and find that
petitioners are the direct transferees from Mr. Kayian, Sr. of
the respective portions of the transferred properties that they
received. Nevertheless, we shall examine only the initial
transfer from Mr. Kayian, Sr. to Mr. Kayian, Jr., as petitioners
request, since our examination of that transfer resolves the
transferee liability issues in these cases.
The parties agree that, in determining whether Mr. Kayian,
Jr. is a transferee at law or in equity, and therefore whether
petitioners are liable as transferees for Mr. Kayian, Sr.'s 1987-
1989 unpaid tax liability, we must consider the application of
the fraudulent conveyance law of Florida set forth in (1) Fla.
Stat. Ann. sec. 726.105 (West 1988) (Fla. Stat. Ann. sec. 726.105
or Florida fraudulent transfer statute) and (2) Fla. Stat. Ann.
sec. 726.106 (West 1988) relating to constructively fraudulent
transfers. We shall address only the applicability of the
Florida fraudulent transfer statute to the initial transfer
because our consideration of that statute disposes of the trans-
feree liability questions presented.
The Florida fraudulent transfer statute provides in per-
tinent part:
(1) A transfer made or obligation incurred by a
debtor is fraudulent as to a creditor, whether the
creditor's claim arose before or after the transfer was
made or the obligation was incurred, if the debtor made
the transfer or incurred the obligation:
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