Dalton v. Comm'r
United States Tax Court
R seeks to collect certain trust fund recovery penalties from Ps. In R's determination pursuant to sec. 6330, I.R.C., R rejected Ps' offer-in-compromise. Ps transferred property to P husband's father F, who in turn transferred the property to a trust 11 years before trust fund recovery penalties arose. The trust was set up to hold the property for the benefit of F's grandsons; i.e., Ps' children.
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R seeks to collect certain trust fund recovery penalties from Ps. In R's determination pursuant to sec. 6330, I.R.C., R rejected Ps' offer-in-compromise. Ps transferred property to P husband's father F, who in turn transferred the property to a trust 11 years before trust fund recovery penalties arose. The trust was set up to hold the property for the benefit of F's grandsons; i.e., Ps' children. R determined that Ps retained a beneficial interest in the trust property under a nominee ownership theory and, therefore, rejected Ps' offer-in-compromise. Ps contend that R's determination was an…
1Opinion of the Court
ARTHUR DALTON, JR. AND BEVERLY DALTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent *
Dalton v. Comm'r
Docket No. 23510-06L.
United States Tax Court
135 T.C. 393; 2010 U.S. Tax Ct. LEXIS 36; 135 T.C. No. 20;
September 23, 2010, Filed
Dalton v. Comm'r, T.C. Memo 2008-165, 2008 Tax Ct. Memo LEXIS 167 (T.C., 2008)
An appropriate order and decision will be entered for petitioners.
R seeks to collect certain trust fund recovery penalties from Ps. In R's determination pursuant to sec. 6330, I.R.C., R rejected Ps' offer-in-compromise. Ps transferred property to P husband's father F, who in…
2Cases cited47 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
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