Holmes v. Commissioner
United States Tax Court
Respondent determined that petitioner was liable, to the extent of $ 37,559.93, plus interest, as transferee for the tax deficiencies, plus interest, of a transferor corporation. Respondent also assessed transferee liabilities in varying amounts against four other transferees of the same corporation.
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Respondent determined that petitioner was liable, to the extent of $ 37,559.93, plus interest, as transferee for the tax deficiencies, plus interest, of a transferor corporation. Respondent also assessed transferee liabilities in varying amounts against four other transferees of the same corporation. Each of the four transferees so assessed made total payments on their respective transferee liabilities which equaled the outstanding tax liability, plus interest, of the transferor corporation. Following such payments, three of the transferees filed administrative claims for refund, and,…
1Opinion of the Court
Stewart C. Holmes, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent
Holmes v. Commissioner
Docket No. 5098-63
United States Tax Court
47 T.C. 622; 1967 U.S. Tax Ct. LEXIS 135;
March 23, 1967, Filed
Decision will be entered for the respondent.
Respondent determined that petitioner was liable, to the extent of $ 37,559.93, plus interest, as transferee for the tax deficiencies, plus interest, of a transferor corporation. Respondent also assessed transferee liabilities in varying amounts against four other transferees of the same corporation. Each of the four transferees so…
2Cases cited10 opinions
- George Moore Ice Cream Co. v. RoseSupreme Court of the United States · 1933
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
- Leach v. CommissionerUnited States Tax Court · 1953
- Kieferdorf v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1944
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