United States v. Westley

BATCHELDER, Circuit Judge.

This case presents the question of the extent of transferee liability for a corporation’s unpaid federal income taxes when the shareholders received a distribution of corporate assets that liquidated the corporation. Such a question is usually straightforward, but this case has been unnecessarily complicated by the Government’s dilatory collection efforts to recover the unpaid corporate income tax liability of Supreme Mortgage and Realty Company, Inc. (“Supreme Inc.”) from its corporate shareholders.

I

Mr. and Mrs. Westley, along with a Mr. Willis, were the sole…