R. G. Cope, Jr., Inc. v. Commissioner
United States Tax Court
Properties were transferred from taxpayers R and A in 1976. By late 1976, petitioner, a corporation owned by the son of R and A, held title to all those properties. Respondent thereafter determined deficiencies against the transferors. Held, petitioner is liable as a transferee for the income taxes due from R and A for the taxable years 1972 through 1975.
1Opinion of the Court
R.G. COPE, JR., INC. ALLEGED TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
R. G. Cope, Jr., Inc. v. Commissioner
Docket No. 1261-80.
United States Tax Court
T.C. Memo 1984-476; 1984 Tax Ct. Memo LEXIS 189; 48 T.C.M. (CCH) 1053; T.C.M. (RIA) 84476;
September 10, 1984.
Properties were transferred from taxpayers R and A in 1976. By late 1976, petitioner, a corporation owned by the son of R and A, held title to all those properties. Respondent thereafter determined deficiencies against the transferors. Held, petitioner is liable as a transferee for the income taxes due from R…
2Cases cited19 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Mysse v. CommissionerUnited States Tax Court · 1972
- JC Jacobs Banking Co. v. CampbellSupreme Court of Alabama · 1981
- Papineau v. CommissionerUnited States Tax Court · 1957
- Lowy v. CommissionerUnited States Tax Court · 1960
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