Legal Opinion

Temoyan v. Commissioner

United States Board of Tax Appeals

Decided June 5, 1929No. Docket No. 22239PublishedCited by 4 opinions

Evidence found to be insufficient to establish the liability of petitioners as transferees, under section 280 of the Revenue Act of 1926, of assets of the taxpayer.

1Opinion of the Court

*924OPINION.

Phillips:

The facts were stipulated. The stipulation contained the additional negative statement which seems to have no place in the findings of fact:

There is no agreement on the stipulation to the effect that the assets, any and all of which are held by the trustees, are the same assets as were formerly held or received in liquidation by the éxecutors of the estate of John Temoyan.

This liability is asserted under the provisions of section 280 of the Revenue Act of 1926 which provides:

Seo. 280. (a) The amounts of the following liabilities shall, except as hereinafter in this section…

2Cited by4 opinions

  1. Ashton v. CommissionerUnited States Board of Tax Appeals · 1933
  2. Davidoff v. CommissionerUnited States Tax Court · 1951
  3. Temoyan v. CommissionerUnited States Board of Tax Appeals · 1929
  4. Wyman v. CommissionerUnited States Tax Court · 1950

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