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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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