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the 1998 transfers of Richard’s interests therein rendered
Richard insolvent. Richard’s September 28, 1998, financial
statements given to respondent showed that after the transfers
Richard had assets of only $8,885 and liabilities of $93,352.
Respondent made reasonable efforts to collect from Richard
his unpaid Federal income taxes for 1995 and 1996, and it is
established that further collection efforts, apart from the
instant transferee proceedings, would have been futile.
Petitioners contend that respondent has not established that
Richard’s transfers of his interests in the farm acreage and in
the residence acreage were made to defraud respondent, that
Richard’s transfers to his daughters were made for less than full
and adequate consideration, or that the transfers rendered
Richard insolvent. Further, petitioners contend that respondent
has not established the value of the real property on the date of
the transfers.
It is clear that, as of September 9, 1998, Richard’s only
significant assets were his one-half interests in the farm
acreage and in the residence acreage that he transferred to his
daughters. The financial statement Richard submitted to
respondent reflected a total value for Richard’s other assets of
less than $10,000.
Respondent’s valuation expert, as of September of 1998,
credibly valued the farm acreage at $176,000, based on a 5-lot
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