Larry D. Johnson v. Commissioner

118 T.C. No. 4

UNITED STATES TAX COURT LARRY D. JOHNSON, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14096-99. Filed January 24, 2002. R determined that P was liable as a transferee of assets from C and, therefore, was liable for C’s tax liabilities. P was the 100-percent owner and president of C. The transfer to P was from a settlement that P, C, and C’s subsidiaries had reached with a creditor. P contends that the portion he received was in consideration of his releasing a claim of his own against the creditor for damages to business reputation, so that,…