In the Matter of Chicagoland Ideel Cleaners, Inc., Bankrupt. United States of America v. Craig Phelps, Receiver in Bankruptcy

CUMMINGS, Circuit Judge.

Taxpayer, Chieagoland Ideel Cleaners, Inc., is an Illinois corporation with its principal place of business in Chicago. On March 12, May 21, May 28, and June 4, 1971, assessments were made against the taxpayer totaling $140,831.5,9 for withholding and federal unemployment taxes for periods from September 30, 1970, to March 31, 1971. On June 28, 1971, pursuant to the written consents of its directors, taxpayer assigned and transferred all of its assets to Nathan Yorke as assignee for the benefit of its creditors. Thereafter Yorke proceeded to liquidate its assets. On…