In this case, the president of a corporation impeded an IRS audit of the corporation by creating and backdating promissory notes, issuing false Forms 1099, among other things. From 2004 to 2008 the corporations earned over $100 million but didn't file any tax corporate tax returns. The IRS claimed that the corporation owed $120 million in taxes, interest and penalties. The petitioner was a minority shareholder that had received bonuses and dividends during the years that the corporation was not paying taxes. The IRS sought to recover $5 million from the two minority shareholders. The petitioner received over $3.5 million in dividends during the years at issue while the company was insolvent and another minority shareholder received about $.5 million. Under state (FL) law, the IRS did not have to pursue all reasonable collection efforts against the corporation, but could go directly after the minority shareholders to the extent of dividends received during the years at issue. Kardash v. Comr., T.C. Memo. 2015-51. On reconsideration, the court determined that the corporation was solvent in 2005, but determined that the transfers were constructively fraudulent as a part of a series of transactions that led to the corporation's insolvency. Consequently, the post-2004 transfers were fraudulent because they were for less than fair market value and resulted in the corporation's insolvency. Kardash v. Comr., T.C. Memo. 2015-197.