1. Whether the Sixth Circuit's decision conflicts with
the decisions of the First, Second, Fourth, and
Ninth Circuits regarding whether an alleged
transferee's knowledge is required for collapsing
transactions under the Uniform Fraudulent
Transfer Act.

2. Whether the Sixth Circuit's reliance on state tax
cases rather than creditor rights cases to justify
collapsing under Tennessee's Uniform Fraudulent
Transfer Act ("TUFTA") conflicts with
Commissioner v. Stern , 357 U.S. 39 (1958) and
Frank Sawyer Trust of May 1992 v. Commissioner ,
712 F.3d 597 (CA1 2013).

3. Whether the Sixth Circuit's imposition of strict
liability under 26 U.S.C. § 6901 conflicts with Stern
and the Fourth Circuit's decision in Starnes v.
Commissioner , 680 F.3d 417 (CA4 2012).

4. Whether the Sixth Circuit's application of federal
doctrines to collapse transactions under TUFTA
violates Stern's required two-step analysis and the
decisions of the First, Second, Fourth, Seventh, and
Ninth Circuits interpreting Stern to prohibit such
application.

Whether the Sixth Circuit's decision conflicts with the decisions of the First, Second, Fourth, and Ninth Circuits regarding whether an alleged transferee's knowledge is required for collapsing transactions under the Uniform Fraudulent Transfer Act