Peter J. Bresson (Transferee),petitioner-Appellant v. Commissioner of Internal Revenue

STOTLER, District Judge:

I

SUMMARY

This case involves efforts by the Internal Revenue Service (IRS) to collect taxes owed by Petitioner’s corporation directly from Petitioner. The taxes arose in connection with the corporation’s transfer of real property to Petitioner and Petitioner’s subsequent sale of that property to an unrelated third party. The IRS’s right to assess taxes directly against Petitioner de rives from the transferee liability provisions of 26 U.S.C. § 6901, and from the provisions of the California Uniform Fraudulent Transfer Act (CUFTA), Cal. Civ.Code §§ 3439.01-12, under which…