Maynard Hospital, Inc. v. Commissioner
United States Tax Court
Held: 1. Petitioners are not entitled in these cases to recoupment of taxes paid on corporate distributions in 1960 because of our holding that they are liable as transferees to the extent of these distributions for unpaid taxes of the corporation. 2. Since no one of petitioner-transferees received transferred assets equal to the corporate tax liability, the rate and starting date of interest on the transfers is to be determined under State law, here the State of Washington.…
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Held: 1. Petitioners are not entitled in these cases to recoupment of taxes paid on corporate distributions in 1960 because of our holding that they are liable as transferees to the extent of these distributions for unpaid taxes of the corporation. 2. Since no one of petitioner-transferees received transferred assets equal to the corporate tax liability, the rate and starting date of interest on the transfers is to be determined under State law, here the State of Washington. 3. Under the law of Washington interest prior to judgment is allowable only on "liquidated" claims or claims due upon a…
1Opinion of the Court
SUPPLEMENTAL OPINION
Scott, Judge:
These proceedings are under Rule 50 of tbe Court’s Rules of Practice. Tbe opinion of this Court in the above-entitled cases was filed on September 25, 1969. On May 5, 1970, respondent filed a computation for entry of decision under Rule 50, and on June 15, 1970, petitioners filed their computation. There is no disagreement between the parties with respect to the computations for entry of decision in the case of Maynard Hospital, Inc., docket No. 4685-65. In the cases of James E. Hunter and Nadine N. Hunter, docket No. 3141-64; Estate of Gordon G. Thompson,…
2Cases cited13 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Prier v. Refrigeration Engineering Co.Washington Supreme Court · 1968
- Mall Tool Co. v. Far West Equipment Co.Washington Supreme Court · 1954
- Stein v. CommissionerUnited States Tax Court · 1962
- Grays Harbor County v. Bay City Lumber Co.Washington Supreme Court · 1955
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3Cited by6 opinions
- Mysse v. CommissionerUnited States Tax Court · 1972
- Delpit v. CommissionerUnited States Tax Court · 1992
- Kardash v. Comm'rUnited States Tax Court · 2015
- Maynard Hospital, Inc. v. CommissionerUnited States Tax Court · 1970
- Mysse v. CommissionerUnited States Tax Court · 1972
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