Robert John Kayian, Transferee - Page 41




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          Kayian are liable as transferees in amounts not exceeding $10,933           
          and $8,200, respectively, plus interest therein as provided by              
          law, for Mr. Kayian, Sr.'s 1987-1989 unpaid tax liability.                  
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             for respondent.                          
























               8(...continued)                                                        
          instant record by the Florida fraudulent transfer statute, we               
          find on that record that Mr. Kayian, Sr. made the initial trans-            
          fer with a fraudulent intent within the meaning of the Florida              
          fraudulent transfer statute.  In making our various findings                
          under the Florida fraudulent transfer statute, we have considered           
          all of the arguments and contentions of petitioners with respect            
          to that statute that are not addressed herein, and we find them             
          to be without merit.                                                        




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