The home was purchased in the name of Joseph Merlino. On the advice of a lawyer, Fred Levin, title was transferred to the mother and then to a trust with Joseph as trustee for Maria and another sister. In December 1988, Joseph Merlino gave his one-third share of the trust to his sister, Maria. The fair market value of the house was $130,000, and the title was conveyed for $1.

Here's the rub. Mr. Merlino and two associates stole $352,150 in an armored car robbery in 1987. In 1990, he was convicted, which made him liable for income tax on his share of the loot. Over the years, the amount of tax he owes has swelled because of penalties and interest to $139,964.

Judge Parker found that the title to the house was transferred fraudulently to keep the house beyond the reach of Federal authorities. Because Joseph Merlino never filed a tax return for 1987, his tax liability arose on April 15, 1988 -- before the house was transferred to his sister. And because she did not pay her brother for the house, Judge Parker concluded that the transfer was fraudulent.

In a partial victory for Ms. Merlino, however, the judge held that she was not liable for the full $139,964. Her liability is $43,000, equivalent to the value of Mr. Merlino's one-third stake in the house at the time of the transfer, plus interest.

Mark E. Cedrone, Ms. Merlino's lawyer, said he was pleased that the judge limited his client's liability but would still seek a reversal. "Her brother didn't even know he was a suspect in the armored car robbery when he transferred his interest in the house," Mr. Cedrone said, arguing that the transfer could not have been fraudulent. "And my client is no Mafia princess. She's goes to work every morning as a legal secretary at one of the most prominent law firms in Philadelphia. The finding is really unfair."