Legal Opinion
Estate of Work v. Commissioner
United States Tax Court
Decided April 23, 1951No. Docket Nos. 102805, 102807PublishedCited by 2 opinions
1Opinion of the Court
OPINION.
Arundell, Judge:
The principal issue herein, relating to the Commissioner’s burden of showing the insolvency of the transferors and exhausting all reasonable remedies for the collection of the tax from the transferors before proceeding against the petitioners as transferees, has been fully considered and decided adversely to the petitioners in Samuel Wilcox, 16 T. C. 572. Therefore, we shall pass immediately to a consideration of the second issue.
Petitioners point to the fact that the court decree of April 2, 1917, directed them to transfer and pay over 1,994 of the 2,990 shares of…
2Cases cited2 opinions
- Wilcox v. CommissionerUnited States Tax Court · 1951
- Estate of Smith v. CommissionerUnited States Tax Court · 1951
3Cited by2 opinions
- Frank E. Sellers, Transferee of the Assets of Norpaco Builders, Inc., Transferor v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1979
- Hutcherson v. CommissionerUnited States Tax Court · 1984