Bellin v. Commissioner
United States Tax Court
Petitioners purchased all the capital stock of Hamilton Homes, Inc., and immediately liquidated and dissolved the corporation, receiving assets having a value in excess of the corporation's subsequently determined tax liability. They signed T.D.
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Petitioners purchased all the capital stock of Hamilton Homes, Inc., and immediately liquidated and dissolved the corporation, receiving assets having a value in excess of the corporation's subsequently determined tax liability. They signed T.D. Form 2045, Transferee Agreement, in which they agreed to pay all taxes due from the corporation, to the extent of their liability at law or in equity as transferees within the meaning of sec. 6901, I.R.C. 1954. Prior to issuance of notice of transferee liability, petitioners transferred all of the assets to another corporation owned by the…
1Opinion of the Court
OPINION
Drennen, Judge:
Petitioners Benjamin and Lillian Beilin and petitioners Meyer and Eva Thomas presently reside in Philadelphia, Pa. Both the Beilins and the Thomases will hereafter be referred to collectively as petitioners.
Respondent determined that petitioners were liable as transferees of the assets of Hamilton Homes, Inc., transferor, for deficiencies in income tax and addition to tax under section 6651(a), I.R.C. 1954,1 as follows:
Addition to tax Deficiency under sec. 6651(a)
FYE Feb. 28,1969 _ $19,012.11
FYE Feb. 28,1970 _ 307.13
Mar. 1,1970, to
May 29,1970 _ 4,329,45 $1,082.36
23,648.69…
2Cases cited23 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Commissioner v. SternSupreme Court of the United States · 1958
- Gobins v. Comm'rUnited States Tax Court · 1952
- Leach v. CommissionerUnited States Tax Court · 1953
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
18 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Merriam v. CommissionerUnited States Tax Court · 1995
- Yurick v. CommonwealthCommonwealth Court of Pennsylvania · 1989
- Gator Oil Co. v. CommissionerUnited States Tax Court · 1976
- Sellers v. CommissionerUnited States Tax Court · 1977
- Elizalde v. CommissionerUnited States Tax Court · 1984
5 more not listed; retrieve them via the Exa API.