Humbert v. Commissioner
United States Board of Tax Appeals
TRANSFEREES. The taxpayer corporation in 1924 sold its assets and business for cash and immediately liquidated by distribution of the cash to its stockholders and ceased business. Income tax of this corporation for the year 1925 has not been paid. Petitioners, as stockholders, each received in this distribution cash in excess of such unpaid tax.
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TRANSFEREES. The taxpayer corporation in 1924 sold its assets and business for cash and immediately liquidated by distribution of the cash to its stockholders and ceased business. Income tax of this corporation for the year 1925 has not been paid. Petitioners, as stockholders, each received in this distribution cash in excess of such unpaid tax. Held, that petitioners are severally liable for the amount of such tax irrespective of the fact that the corporation on the sale of its assets contracted with the purchaser for the assumption by the latter of the tax liability in question.
1Opinion of the Court
OPINION.
TRAmmell :
By these appeals petitioners ask redetermination of an asserted liability in the amount of $28,371.34, representing unpaid income tax of the Polar Products Company, Inc., for the calendar year 1925, this liability being determined by respondent for assessment against each individually under section 280 of the Revenue Act of 1926, as representing the several obligation of each as distrib-utees in liquidation of assets of the taxpayer corporation. These appeals were consolidated with the appeal of the Reid Ice Cream Corporation, Docket No. 37051, decided this date and in which…
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