Legal Opinion

Scott v. Commissioner

United States Tax Court

Decided April 27, 1978No. Docket No. 11233-76Published

1. In 1970, P's husband sold an undivided life interest in real property and arranged to have the proceeds transferred to P. Held, P is liable as a transferee for her husband's income taxes for 1964 through 1966 to the extent of the proceeds transferred to her. 2. In 1973, P's husband, who owned 49.8 percent of the stock of Scott Roofing, arranged for Scott Roofing to redeem his stock.

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1. In 1970, P's husband sold an undivided life interest in real property and arranged to have the proceeds transferred to P. Held, P is liable as a transferee for her husband's income taxes for 1964 through 1966 to the extent of the proceeds transferred to her. 2. In 1973, P's husband, who owned 49.8 percent of the stock of Scott Roofing, arranged for Scott Roofing to redeem his stock. As part of the redemption agreement, Scott Roofing agreed to subcontract two roofing jobs to Quality, a corporation to be formed. Later, Quality was incorporated. P made a capital contribution of $ 500 and…

1Opinion of the Court

Joy Harper (Owens) Scott, Petitioner v. Commissioner of Internal Revenue, Respondent

Scott v. Commissioner

Docket No. 11233-76

United States Tax Court

70 T.C. 71; 1978 U.S. Tax Ct. LEXIS 132;

April 27, 1978, Filed

Decision will be entered under Rule 155.

1. In 1970, P's husband sold an undivided life interest in real property and arranged to have the proceeds transferred to P. Held, P is liable as a transferee for her husband's income taxes for 1964 through 1966 to the extent of the proceeds transferred to her.

2. In 1973, P's husband, who owned 49.8 percent of the stock of Scott Roofing, arranged…

2Cases cited32 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Stein v. CommissionerUnited States Tax Court · 1962
  4. Aman v. . WalkerSupreme Court of North Carolina · 1914
  5. Pierce v. CommissionerUnited States Tax Court · 1974

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