Moran v. Commissioner
United States Tax Court
Petitioner sought review of an asserted liability as transferee of assets. She failed to reply to the affirmative allegations in the respondent's answer or to oppose the respondent's motion that such allegations be deemed admitted. Held, the admitted allegations of respondent's answer are sufficient proof of transferee liability.
1Opinion of the Court
FINDINGS OF FACT
Simpson, Judge:
The respondent has asserted that Eileen J. Moran, the petitioner, is liable for $12,667.78 as transferee of the assets of James J. and Josephine Moran. The liability of the transferors for tax and penalties was decided by this Court in docket No. 69061.
The respondent mailed a notice of transferee liability to the petitioner on May 28, 1964. On August 27, 1964, a petition was filed with this Court requesting a review of such liability. The respondent’s answer to the petition contained the following affirmative allegations:(a) The petitioner Eileen J. Moran is the…
2Cases cited2 opinions
- Morris v. CommissionerUnited States Tax Court · 1958
- Black v. CommissionerUnited States Tax Court · 1952
3Cited by20 opinions
- Estate of Mandels v. CommissionerUnited States Tax Court · 1975
- Estate of Quirk v. CommissionerUnited States Tax Court · 1973
- Alonso v. CommissionerUnited States Tax Court · 1982
- Collegiate Cap & Gown Co. v. CommissionerUnited States Tax Court · 1972
- Smith v. CommissionerUnited States Tax Court · 1989
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