R.G. Cope, Jr., Inc., Alleged Transferee v. Commissioner of Internal Revenue

DUMBAULD, Senior District Judge:

This is an appeal from the Tax Court which decided that appellant, R.G. Cope, Jr., Inc. (a corporation of which R.G. Cope, Jr. is president and principal stockholder) is liable as transferee under 26 U.S.C. 6901 for tax liabilities of R.G. Cope’s parents, Robert G. Cope, Sr. (Hereinafter sometimes called “father”) and of Aliene D. Cope (“mother”). The tax years involved are 1972-1975. They did not file returns for 1974 and 1975. The father began having financial difficulties in 1969.

As a result of the father’s difficulties, the mother placed a second mortgage…