Legal Opinion

Bellin v. Commissioner

United States Tax Court

Decided December 31, 1975No. Docket Nos. 2159-74, 2177-74Published

Petitioners purchased all the capital stock of Hamilton Homes, Inc., and immediately liquidated and dissolved the corporation, receiving assets having a value in excess of the corporation's subsequently determined tax liability. They signed T.D.

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Petitioners purchased all the capital stock of Hamilton Homes, Inc., and immediately liquidated and dissolved the corporation, receiving assets having a value in excess of the corporation's subsequently determined tax liability. They signed T.D. Form 2045, Transferee Agreement, in which they agreed to pay all taxes due from the corporation, to the extent of their liability at law or in equity as transferees within the meaning of sec. 6901, I.R.C. 1954. Prior to issuance of notice of transferee liability, petitioners transferred all of the assets to another corporation owned by the…

1Opinion of the Court

Benjamin and Lillian Bellin, Petitioners v. Commissioner of Internal Revenue, Respondent; Meyer and Eva Thomas, Petitioners v. Commissioner of Internal Revenue, Respondent

Bellin v. Commissioner

Docket Nos. 2159-74, 2177-74

United States Tax Court

65 T.C. 676; 1975 U.S. Tax Ct. LEXIS 4;

December 31, 1975, Filed

Decisions will be entered for the respondent.

Petitioners purchased all the capital stock of Hamilton Homes, Inc., and immediately liquidated and dissolved the corporation, receiving assets having a value in excess of the corporation's subsequently determined tax liability. They signed T.D.…

2Cases cited26 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Gobins v. Comm'rUnited States Tax Court · 1952
  4. Leach v. CommissionerUnited States Tax Court · 1953
  5. Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941

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