Stansbury v. Commissioner
United States Tax Court
Ps were officers and 100-percent owners of ABC corporation. After ABC agreed to the assessment and collection of taxes and additions to tax owed by ABC, but prior to payment thereof, all of ABC's remaining assets were transferred to Ps, and ABC was dissolved.
Read the full summary
Ps were officers and 100-percent owners of ABC corporation. After ABC agreed to the assessment and collection of taxes and additions to tax owed by ABC, but prior to payment thereof, all of ABC's remaining assets were transferred to Ps, and ABC was dissolved. Ps agree that they are liable as transferees to the extent of the value of the assets received from ABC and that they are liable for interest under sec. 6601, I.R.C., from the date they received notices of transferee liability. Ps argue, however, that they are not liable, under either Federal or State law, for interest prior to the date…
1Opinion of the Court
Gerber, Judge:
Respondent, by means of separate notices of transferee liability, determined that petitioners Doris E. Stansbury and Leland D. Stansbury are liable as transferees of property from ABC Real Estate, Inc. (hereinafter referred to as ABC or transferor), for the following deficiencies in income tax and additions to tax:1
Additions to tax
Sec. Sec. Year Deficiency 6651(a)(1) 6653(a) Sec. 6655 Sec. Accrued 6661(a) interest
1980 $7,227 $1,806.75 $361.35 $418.65 $18,305.60
1981 11,490 2.872.50 574.50 749.95 25,339.66
1982 5,330 1.332.50 266.50 478.28 9,173.02
1983 14,996 3,749.00 749.80 934.83…
2Cases cited25 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Commissioner v. SternSupreme Court of the United States · 1958
- Fish v. EastCourt of Appeals for the Tenth Circuit · 1940
- Mesa Sand & Gravel Co. v. Landfill, Inc.Supreme Court of Colorado · 1989
20 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Merriam v. CommissionerUnited States Tax Court · 1995
- Stansbury v. CommissionerCourt of Appeals for the Tenth Circuit · 1996
- Diebold v. Comm'rUnited States Tax Court · 2010
- Espinosa v. CommissionerUnited States Tax Court · 2000
- Hawk v. Comm'rUnited States Tax Court · 2017
5 more not listed; retrieve them via the Exa API.