N. B. Drew v. The United States. The Valley National Bank of Arizona, of the Estate of William F. Drew, Deceased v. The United States

LARAMORE, Judge.

These are consolidated actions brought by taxpayers for the refund of income taxes paid by them as transferees of a dissolved corporation. The case is before us on taxpayers’ motion for summary judgment in which the sole question presented is whether the Commissioner of Internal Revenue is barred by limitations from asserting transferee liability against taxpayers for a deficiency in income taxes for 1956 of the now dissolved F. P. Drew & Sons Lumber Company, Inc. Taxpayers rely on subsection (d) of section 6501 of the 1954 Code which provides an exception to the “General…