Legal Opinion

Maynard Hospital, Inc. v. Commissioner

United States Tax Court

Decided August 31, 1970No. Docket Nos. 4685-65, 3141-64, 3295-64, 3306-64, 3313-64, 378-65, 4814-65, 4684-65, 4686-65, 4687-65, 4688-65, 4689-65, 4690-65Published

Held: 1. Petitioners are not entitled in these cases to recoupment of taxes paid on corporate distributions in 1960 because of our holding that they are liable as transferees to the extent of these distributions for unpaid taxes of the corporation. 2. Since no one of petitioner-transferees received transferred assets equal to the corporate tax liability, the rate and starting date of interest on the transfers is to be determined under State law, here the State of Washington.…

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Held: 1. Petitioners are not entitled in these cases to recoupment of taxes paid on corporate distributions in 1960 because of our holding that they are liable as transferees to the extent of these distributions for unpaid taxes of the corporation. 2. Since no one of petitioner-transferees received transferred assets equal to the corporate tax liability, the rate and starting date of interest on the transfers is to be determined under State law, here the State of Washington. 3. Under the law of Washington interest prior to judgment is allowable only on "liquidated" claims or claims due upon a…

1Opinion of the Court

Maynard Hospital, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Maynard Hospital, Inc. v. Commissioner

Docket Nos. 4685-65, 3141-64, 3295-64, 3306-64, 3313-64, 378-65, 4814-65, 4684-65, 4686-65, 4687-65, 4688-65, 4689-65, 4690-65

United States Tax Court

54 T.C. 1675; 1970 U.S. Tax Ct. LEXIS 71;

August 31, 1970, Filed

Held: 1. Petitioners are not entitled in these cases to recoupment of taxes paid on corporate distributions in 1960 because of our holding that they are liable as transferees to the extent of these distributions for unpaid taxes of the corporation.

2. Since…

2Cases cited14 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Prier v. Refrigeration Engineering Co.Washington Supreme Court · 1968
  3. Mall Tool Co. v. Far West Equipment Co.Washington Supreme Court · 1954
  4. Stein v. CommissionerUnited States Tax Court · 1962
  5. Grays Harbor County v. Bay City Lumber Co.Washington Supreme Court · 1955

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