McKnight v. Commissioner
United States Tax Court
1. Petitioner, recipient of assets of insolvent taxpayer-corporation, of which petitioner's decedent had been stockholder, held liable for unpaid taxes of the taxpayer as a transferee under Internal Revenue Code, section 311, notwithstanding that all property so obtained has been used to pay claims against the taxpayer or priority claims of the petitioner estate.
Read the full summary
1. Petitioner, recipient of assets of insolvent taxpayer-corporation, of which petitioner's decedent had been stockholder, held liable for unpaid taxes of the taxpayer as a transferee under Internal Revenue Code, section 311, notwithstanding that all property so obtained has been used to pay claims against the taxpayer or priority claims of the petitioner estate. Jessie Smith, Executrix, 24 B. T. A. 807, distinguished. 2. Held, that no issue arises in this proceeding with respect to the liability of the administrator as a fiduciary under R. S. 3467, in the absence of a deficiency notice…
1Opinion of the Court
Estate of L. E. McKnight, L. T. McCourt, Administrator, Petitioner, v. Commissioner of Internal Revenue, Respondent
McKnight v. Commissioner
Docket No. 7455
United States Tax Court
8 T.C. 871; 1947 U.S. Tax Ct. LEXIS 223;
April 23, 1947, Promulgated
Decision will be entered for the respondent.
1. Petitioner, recipient of assets of insolvent taxpayer-corporation, of which petitioner's decedent had been stockholder, held liable for unpaid taxes of the taxpayer as a transferee under Internal Revenue Code, section 311, notwithstanding that all property so obtained has been used to pay claims against the…
2Cases cited4 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- McKnight v. CommissionerUnited States Tax Court · 1947
- United States v. BarnesDistrict Court, S.D. New York · 1887
- Wisconsin v. IllinoisSupreme Court of the United States · 1926