Legal Opinion

Noell v. Commissioner

United States Tax Court

Decided June 6, 1955No. Docket No. 42434PublishedCited by 20 opinions

After receipt of notice of transferee liability, a transferee is not relieved of liability by subsequent retransfers to the transferor.

1Opinion of the Court

supplemental opinion.

ÁRUndell, Judge:

In an earlier opinion reported at 22 T. C. 1035, we determined that the petitioner herein, Louise Noell, was liable as the transferee of her husband, Charles P. Noell, for his outstanding income tax liability for 1949. The findings of fact reported there are incorporated herein by reference.

In finding petitioner liable as a transferee, however, we decided, on the basis of our decision in Fada Gobins, 18 T. C. 1159, affd. 217 F. 2d 952, that since $18,934.37 had been returned to Noell by petitioner, her liability as a transferee should be diminished to that…

2Cases cited4 opinions

  1. Gobins v. Comm'rUnited States Tax Court · 1952
  2. Dougherty v. CooperSupreme Court of Missouri · 1883
  3. Schneider v. PattonSupreme Court of Missouri · 1903
  4. Stein v. BurnettMissouri Court of Appeals · 1891

3Cited by20 opinions

  1. Kreps v. CommissionerUnited States Tax Court · 1964
  2. Papineau v. CommissionerUnited States Tax Court · 1957
  3. Robert Ginsberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  4. Ginsberg v. CommissionerUnited States Tax Court · 1961
  5. Mendelson v. Comm'rUnited States Tax Court · 1969

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