Costanzo v. Commissioner
United States Board of Tax Appeals
1. The petitioners, on the dissolution of a corporation of which they were the principal stockholders, received liquidating dividends in excess of the amount of additional taxes subsequently assessed against the dissolved corporation.
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1. The petitioners, on the dissolution of a corporation of which they were the principal stockholders, received liquidating dividends in excess of the amount of additional taxes subsequently assessed against the dissolved corporation. Held that the petitioners are transferees within the meaning of section 280 of the Revenue Act of 1926. 2. Where the period of limitation for assessment of taxes against the taxpayer did not expire until after the enactment of the Revenue Act of 1926, and the liability for unpaid taxes of the taxpayer was asserted against petitioners, as transferees, within one…
1Opinion of the Court
*1295OPINION.
Aeundell :
Petitioners contend that the term “ transferee,” as used • in section 280 of the Eevenue Act of 1926, is limited to heirs, legatees, devisees and distributees, the four classes named in subsection (f) of section 280. The statute does not define the meaning of the word *1296“transferee.” The language of section 280(f) was not intended, as we held in Victor H. Levy, 16 B. T. A. 653, to limit the meaning of the term to the classes mentioned, but was inserted to eliminate any doubt that it included those four classes.
On the dissolution of the Stellar Coal Mining Co., petitioners, as…
2Cases cited2 opinions
- Russell v. United StatesSupreme Court of the United States · 1929
- Clement Gunn v. The United States of AmericaSupreme Court of the United States · 1926
3Cited by12 opinions
- Lowy v. CommissionerUnited States Tax Court · 1960
- Transport Manufacturing & Equipment Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1970
- Fidelity Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1944
- Louisiana & A. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Transport Manufacturing & Equipment Company, a Delaware Corporation, Transferee v. Commissioner of Internal Revenue, Transport Manufacturing & Equipment Company, an Illinois Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1970
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