Legal Opinion

Van Aernam v. Commissioner

United States Tax Court

Decided December 14, 2000No. 8972-97Unpublished

R claims that P is liable as a transferee of H for deficiencies in H's income taxes. P and H contracted to buy property. P and two others contributed to the purchase price. Deed number one conveyed the property from the seller to P, alone. Deed number two conveyed the property from the seller to H, alone. Subsequently, by deed number three, H conveyed the property to P, alone.

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R claims that P is liable as a transferee of H for deficiencies in H's income taxes. P and H contracted to buy property. P and two others contributed to the purchase price. Deed number one conveyed the property from the seller to P, alone. Deed number two conveyed the property from the seller to H, alone. Subsequently, by deed number three, H conveyed the property to P, alone. R claims that deed number three was a fraudulent transfer under the Uniform Fraudulent Transfer Act, Fla. Stat. Ann. secs. 726.101 through 726.112 (West 2000). R relies exclusively on the stipulated facts to establish…

1Opinion of the Court

DIXIE VAN AERNAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Van Aernam v. Commissioner

No. 8972-97

United States Tax Court

T.C. Memo 2000-377; 2000 Tax Ct. Memo LEXIS 446; 80 T.C.M. (CCH) 847; T.C.M. (RIA) 54153;

December 14, 2000, Filed

Decision will be entered for petitioner.

R claims that P is liable as a transferee of H for

deficiencies in H's income taxes. P and H contracted to buy

property. P and two others contributed to the purchase price.

Deed number one conveyed the property from the seller to P,

alone. Deed number two conveyed the property from the seller to

H, alone.…

2Cases cited9 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Gumm v. CommissionerUnited States Tax Court · 1989
  3. Morgan (Carol) v. Barsky (Marvin J.)Court of Appeals for the Ninth Circuit · 1991
  4. Hagaman v. CommissionerUnited States Tax Court · 1993
  5. Lime Cola Co. v. CommissionerUnited States Tax Court · 1954

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