Legal Opinion

Kreps v. Commissioner

United States Tax Court

Decided June 30, 1964No. Docket No. 85290PublishedCited by 96 opinions

Held: (1) The assessment and collection of deficiencies in income tax and additions to tax determined against Metropolitan Air Freight Depot, Inc., are not barred by limitations. (2) The assessment and collection of transferee liability asserted against the petitioner are not barred by limitations.

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Held: (1) The assessment and collection of deficiencies in income tax and additions to tax determined against Metropolitan Air Freight Depot, Inc., are not barred by limitations. (2) The assessment and collection of transferee liability asserted against the petitioner are not barred by limitations. (3) Petitioner is liable as transferee to the extent of at least $ 7,357.54 for income taxes, additions to tax, and interest due from Metropolitan Air Freight Depot, Inc., for the fiscal years ending February 28, 1951, and February 29, 1952.

1Opinion of the Court

Bruce, Judge:

Respondent determined that petitioner is liable to the extent of $7,357.54 as transferee of assets of Metropolitan Air Freight Depot, Inc., for income taxes, additions to tax, and interest due from Metropolitan for the fiscal years ended February 28, 1951, February 29,1952, and February 28,1953.

The questions presented are:(1) Whether petitioner is liable as a transferee to the extent of $7,357.54, or in any amount, for income taxes, additions to tax, and interest due from Metropolitan Air Freight Depot, Inc., for the fiscal years ended February 28, 1951, February 29, 1952, and…

2Cases cited14 opinions

  1. Papineau v. CommissionerUnited States Tax Court · 1957
  2. Leach v. CommissionerUnited States Tax Court · 1953
  3. Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
  4. Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
  5. Feist v. DruckermanCourt of Appeals for the Second Circuit · 1934

9 more not listed; retrieve them via the Exa API.

3Cited by96 opinions

  1. Mysse v. CommissionerUnited States Tax Court · 1972
  2. Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
  3. C.B.C. Super Markets, Inc. v. CommissionerUnited States Tax Court · 1970
  4. Gumm v. CommissionerUnited States Tax Court · 1989
  5. Kean v. CommissionerUnited States Tax Court · 1988

91 more not listed; retrieve them via the Exa API.

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