Scott v. Commissioner
United States Tax Court
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
Simpson, Judge:
The Commissioner determined that the petitioner was liable as a transferee of E. L. Scott for deficiencies in income tax, additions to tax, and interest in the total amount of $146,530.60. There is no dispute over the liability of E. L. Scott for such deficiencies, additions to tax, or interest. The principal issues remaining for decision are: (1) Whether the petitioner’s husband transferred to her the proceeds from the sale of a life interest in certain real property; and (2) whether the petitioner is liable as a transferee for the profits received by her from a business which…
2Cases cited31 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Commissioner v. SternSupreme Court of the United States · 1958
- Stein v. CommissionerUnited States Tax Court · 1962
- Aman v. . WalkerSupreme Court of North Carolina · 1914
- Pierce v. CommissionerUnited States Tax Court · 1974
26 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Bosurgi v. CommissionerUnited States Tax Court · 1986
- Cyndee Smith v. Castaways Family Diner and Carrol A. Gonzalez, Doing Business as Castaways Family DinerCourt of Appeals for the Seventh Circuit · 2006
- Poinier v. CommissionerUnited States Tax Court · 1986
- Hill v. United StatesDistrict Court, W.D. North Carolina · 1993
- Elizalde v. CommissionerUnited States Tax Court · 1984
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