Bryan S. Alterman Trust v. Comm'r
United States Tax Court
In Alterman Trust v. Commissioner, T.C. Memo. 2015-231, we held that R failed to meet his burden of proof to establish that P was liable under I.R.C. sec. 6901 as a transferee for Alterman Corp.'s 2003 income tax liability.
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In Alterman Trust v. Commissioner, T.C. Memo. 2015-231, we held that R failed to meet his burden of proof to establish that P was liable under I.R.C. sec. 6901 as a transferee for Alterman Corp.'s 2003 income tax liability. P, a trust whose case was consolidated with other cases for purposes of that opinion, has moved for an award of administrative and litigation costs under I.R.C. sec. 7430. Generally, individual taxpayers seeking costs must have a net worth of $2 million or less at the time the civil action was filed, as required by 28 U.S.C. sec. 2412(d)(2)(B). I.R.C. sec.…
1Opinion of the Court
BRYAN S. ALTERMAN TRUST U/A/D MAY 9, 2000, BRYAN S. ALTERMAN, TRUSTEE, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bryan S. Alterman Trust v. Comm'r
Docket No. 6940-10
United States Tax Court
146 T.C. 226; 2016 U.S. Tax Ct. LEXIS 15; 146 T.C. No. 14;
May 2, 2016, Filed
John Alterman Trust v. Comm'r, T.C. Memo 2015-231, 2015 Tax Ct. Memo LEXIS 239 (T.C., 2015)
An appropriate order will be issued denying petitioner's motion, and decision will be entered for petitioner.
In Alterman Trust v. Commissioner, T.C. Memo. 2015-231, we held that R failed to meet his burden of proof to…
2Cases cited5 opinions
- Estate of Edward Kunze, Deceased, Carol Ann Hause v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2000
- Haas & Assocs. Accountancy Corp. v. Comm'rUnited States Tax Court · 2001
- Haas & Associates v. CommissionerCourt of Appeals for the Ninth Circuit · 2003
- John Alterman Trust v. Comm'rUnited States Tax Court · 2015
- Estate of Kunze v. CommissionerUnited States Tax Court · 1999