Hunt v. Commissioner
United States Tax Court
P's brother transferred real property to P at a time when he owed deficiencies in tax. R determined that P was liable as a transferee of assets under I.R.C. section 6901(a). Held, R has failed his burden of proving that the deed was voluntary and that P's brother was insolvent at the time of the transfer.
1Opinion of the Court
BRENDA POWERS HUNT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hunt v. Commissioner
Docket No. 1064-86
United States Tax Court
T.C. Memo 1988-360; 1988 Tax Ct. Memo LEXIS 388; 55 T.C.M. (CCH) 1508; T.C.M. (RIA) 88360;
August 9, 1988
P's brother transferred real property to P at a time when he owed deficiencies in tax. R determined that P was liable as a transferee of assets under I.R.C. section 6901(a). Held, R has failed his burden of proving that the deed was voluntary and that P's brother was insolvent at the time of the transfer.
Robert J. Hipple, for the petitioner.
Bonnie L.…
2Cases cited18 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Chambers v. Citizens & Southern National BankSupreme Court of Georgia · 1978
- C.B.C. Super Markets, Inc. v. CommissionerUnited States Tax Court · 1970
- Lowy v. CommissionerUnited States Tax Court · 1960
- Swinks v. CommissionerUnited States Tax Court · 1968
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