Legal Opinion

Bartmer Automatic Self Service Laundry, Inc. v. Commissioner

United States Tax Court

Decided November 23, 1960No. Docket Nos. 64464, 64465, 65229Published

1. Respondent made a jeopardy assessment against transferor on June 6, 1951, and was entitled to 6 years thereafter within which to take action against the transferee. Held, a deficiency notice asserting transferee liability sent to petitioner in September 1956 was timely. 2. The transferor transferred the assets after a jeopardy assessment, jeopardy notice, and demand, after the liens were filed, levies served, and after engaging in conduct aimed at concealing assets.

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1. Respondent made a jeopardy assessment against transferor on June 6, 1951, and was entitled to 6 years thereafter within which to take action against the transferee. Held, a deficiency notice asserting transferee liability sent to petitioner in September 1956 was timely. 2. The transferor transferred the assets after a jeopardy assessment, jeopardy notice, and demand, after the liens were filed, levies served, and after engaging in conduct aimed at concealing assets. Since the transfer took place under circumstances exhibiting the "badges of fraud" under Missouri law, held the transfer…

1Opinion of the Court

Bartmer Automatic Self Service Laundry, Inc., et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Bartmer Automatic Self Service Laundry, Inc. v. Commissioner

Docket Nos. 64464, 64465, 65229

United States Tax Court

35 T.C. 317; 1960 U.S. Tax Ct. LEXIS 18;

November 23, 1960, Filed

Decisions will be entered under Rule 50.

1. Respondent made a jeopardy assessment against transferor on June 6, 1951, and was entitled to 6 years thereafter within which to take action against the transferee. Held, a deficiency notice asserting transferee liability sent to petitioner in September 1956 was…

2Cases cited16 opinions

  1. United States v. UpdikeSupreme Court of the United States · 1930
  2. Papineau v. CommissionerUnited States Tax Court · 1957
  3. Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
  4. Vaughn C. Payne and Edith Pruitt Payne v. United StatesCourt of Appeals for the Eighth Circuit · 1957
  5. Conrad v. Diehl.Supreme Court of Missouri · 1939

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