Holmes v. Commissioner
United States Tax Court
Respondent determined that petitioner was liable, to the extent of $ 37,559.93, plus interest, as transferee for the tax deficiencies, plus interest, of a transferor corporation. Respondent also assessed transferee liabilities in varying amounts against four other transferees of the same corporation.
Read the full summary
Respondent determined that petitioner was liable, to the extent of $ 37,559.93, plus interest, as transferee for the tax deficiencies, plus interest, of a transferor corporation. Respondent also assessed transferee liabilities in varying amounts against four other transferees of the same corporation. Each of the four transferees so assessed made total payments on their respective transferee liabilities which equaled the outstanding tax liability, plus interest, of the transferor corporation. Following such payments, three of the transferees filed administrative claims for refund, and,…
1Opinion of the Court
MulROnev, Judge:
Respondent determined that petitioner is liable to the extent of $37,559.93, plus interest, as transferee of assets of the Daro Corp. for income tax deficiencies and interest due from the Daro Corp. for the fiscal years ended March 31, 1956 and 1957. The issue is whether petitioner is liable, to tlie extent determined, as transferee for the taxes and interest due from the transferor corporation.
FINDINGS OF FACT
Some of the facts were stipulated and they are so found.
Stewart C. Holmes is a resident of Birmingham, Ala. The Daro Corp. was organized under the laws of Louisiana on…
2Cases cited9 opinions
- George Moore Ice Cream Co. v. RoseSupreme Court of the United States · 1933
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
- Leach v. CommissionerUnited States Tax Court · 1953
- Kieferdorf v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1944
4 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Hine v. CommissionerUnited States Tax Court · 1970
- Estate of O'Neal v. United StatesDistrict Court, N.D. Alabama · 2000
- Delpit v. CommissionerUnited States Tax Court · 1991
- Dowell v. CommissionerUnited States Tax Court · 1980
- Page Family Preservation Trust B v. CommissionerUnited States Tax Court · 1991
9 more not listed; retrieve them via the Exa API.