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tax and penalties for 1983 through 1990 on the last day of each
of those taxable periods during which the tax liability accrued.
Thus, respondent asserts, Frank and Katherine owed the tax
liabilities, additions to tax and penalties to respondent before
Frank and Katherine made the subject transfers to Larry, Ronnie,
and Sylvia. We agree that respondent was a creditor of Frank and
Katherine at least by April 16, 1984, because Federal taxes are
considered due and owing, and constitute a liability regardless
of when they are assessed, no later than the date the tax return
for the particular period is required to be filed. See United
States v. Hickox, 356 F.2d 969, 972-973 (5th Cir. 1966); Hagaman
v. Commissioner, 100 T.C. at 185; Papineau v. Commissioner, 28
T.C. 54, 58 (1957); Veigle v. United States, 873 F. Supp. at 625;
Harper v. United States, 769 F. Supp. at 366-367; United States
v. Ressler, 433 F. Supp. at 463.
Respondent contends that the following badges of fraud apply
to the transfers Frank and Katherine made to Larry, Ronnie, and
Sylvia: (1) Lack of consideration, (2) close family relationship,
(3) concealment of assets as a result of the difficulty in
tracing cash, (4) the transfer of virtually all of their assets,
and (5) insolvency resulting from the pattern of transfers.
Petitioners deny that Frank and Katherine concealed any
gifts to Larry, Ronnie, and Sylvia. They also contend that Frank
and Katherine were not insolvent after the transfers were made.
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