Jean A. Stanko v. Commissioner of Internal Revenue

LOKEN, Circuit Judge.

This case raises novel and difficult questions concerning transferee liability under the Internal Revenue Code. The transferee, Jean Stanko, appeals the Tax Court’s determination that she is liable for $3,442,-874 in unpaid taxes owed by Stanko Packing, Inc. (“Stanko PacMng”), because she is the successor transferee of an installment note fraudulently conveyed by Stan-ko PacMng to its sole shareholder, Jean’s former spouse, Rudy Stanko. We agree Jean is hable as successor transferee, but we conclude the Tax Court miscalculated the amount of her transferee liability under…