T.C. Memo. 2000-377
UNITED STATES TAX COURT
DIXIE VAN AERNAM, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8972-97. Filed December 14, 2000.
R claims that P is liable as a transferee of H
for deficiencies in H’s income taxes. P and H
contracted to buy property. P and two others
contributed to the purchase price. Deed number one
conveyed the property from the seller to P, alone.
Deed number two conveyed the property from the seller
to H, alone. Subsequently, by deed number three, H
conveyed the property to P, alone. R claims that deed
number three was a fraudulent transfer under the
Uniform Fraudulent Transfer Act, Fla. Stat. Ann. secs.
726.101 through 726.112 (West 2000). R relies
exclusively on the stipulated facts to establish the
elements of a fraudulent transfer. P’s testimony
contradicts inferences to be drawn from the stipulated
facts. R has failed to carry his burden of proof that
the transfer was fraudulent. Held: P has no
transferee liability under sec. 6901(a), I.R.C.
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