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transferees under either Fla. Stat. sec. 726.105(1)(a) or sec.
726.106(1).
Petitioners, however, contend that the transfers to Larry,
Ronnie, and Sylvia were not fraudulent conveyances because Frank
and Katherine’s primary motives in making the transfers were
personal gratification and estate planning, not to hinder or
delay the collection of a creditor’s claim or otherwise to
defraud any creditor. Petitioners maintain that the transfers
were in accord with gypsy custom of parents giving their eldest
son everything they own before or after they die. Thus,
petitioners contend, Frank and Katherine had no fraudulent intent
in making the transfers to Larry, Ronnie, and Sylvia.
Additionally, petitioners assert that the fact that there were no
known threats of lawsuits or creditors claims against Frank and
Katherine supports the contention that they were not attempting
to defraud creditors when they made the transfers.
There is no dispute that Frank and Katherine transferred
funds or specific property to Larry, Ronnie, and Sylvia without
consideration during and after the years in issue. Indeed,
Katherine testified that she had provided the funds for all of
Larry’s, Ronnie’s, and Sylvia’s purchases of assets, and they
affirmed Katherine’s statement.
Respondent contends that respondent became a creditor of
Frank and Katherine for unpaid tax liabilities and additions to
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