Legal Opinion
Frank Sawyer Trust of May 1992 v. Commissioner of Internal Reven
Court of Appeals for the First Circuit
Decided March 29, 2013No. 12-1586PublishedCited by 27 opinions
1Opinion of the Court
LYNCH, Chief Judge.
This case involves the Internal Revenue Service’s efforts to collect taxes and penalties assessed upon four corporations. The corporations acknowledged that they owed the federal government more than $24 million in taxes and penalties, but before the Internal Revenue Service (IRS) could collect against the corporations, the corporations rendered themselves insolvent by transferring all of their assets to other entities.
The issue in dispute is whether the previous owner of the four corporations, the Frank Sawyer Trust of May 1992, is liable to the IRS for the corporations’…
2Cases cited33 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. SternSupreme Court of the United States · 1958
- HBE Leasing Corp. v. FrankCourt of Appeals for the Second Circuit · 1995
- Warfield v. ByronCourt of Appeals for the Fifth Circuit · 2006
28 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Ralph S. Janvey, in His Capacity as Court-Appointed Receiver for the Stanford International Bank, Limited Official Stanford Investors Committee v. the Golf Channel, Incorporated Tgc, L.L.C., Doing Business as Golf ChannelTexas Supreme Court · 2016
- Foisie v. Worcester Polytechnic Inst.Court of Appeals for the First Circuit · 2020
- Diebold Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2013
- Salus Mundi Foundation v. CommissionerCourt of Appeals for the Ninth Circuit · 2014
- Feldman v. CommissionerCourt of Appeals for the Seventh Circuit · 2015
22 more not listed; retrieve them via the Exa API.