Edward Fridovich, Transferee - Page 7




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          1995, WLLC’s assets were transferred to a Florida limited                   
          partnership, West Lakeland Land Co., Limited Partnership (WLLC              
          Ltd.), in exchange for a 99-percent limited partnership interest in         
          WLLC Ltd.  Fridovich Holdings, Inc. (owned by Debbie Fridovich,             
          petitioner’s sister, and Anthony Fridovich), held a 1-percent               
          general partnership interest in WLLC Ltd.                                   
               On March 19, 1996, the Internal Revenue Service filed Notices          
          of Federal Tax Lien against WWLC Ltd., naming the partnership as            
          nominee of the estate.  On June 13, 1996, WLLC Ltd. brought suit            
          against the United States, see West Lakeland Land Co., Ltd.                 
          Partnership v. United States, case No. 96-1157-CIV-T-21 (M.D.               
          Fla.), to quiet title with respect to the partnership property and          
          for release of liens.                                                       
               On October 22, 1996, WLLC Ltd. filed for bankruptcy under              
          chapter 11.  See In re West Lakeland Land Co., Ltd. Partnership,            
          case No. 96-14434-8CI (Bankr. M.D. Fla.), appeal docketed, No. 98-          
          1609-CIV-T25E (M.D. Fla. Aug. 3, 1998).  On November 12, 1996, the          
          partnership filed an adversary complaint against the United States          
          in its bankruptcy case, challenging the validity of the                     
          Government’s nominee liens.  See West Lakeland Land Co., Ltd.               
          Partnership v. United States, 216 Bankr. 892 (Bankr. M.D. Fla.              
          1998), appeal docketed, No. 98-548-CIV-T23A (M.D. Fla. Mar. 16,             
          1998).  On February 3, 1998, the bankruptcy court entered a                 
          judgment and opinion, finding that the nominee liens were invalid           






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