Legal Opinion

Johnson v. Comm'r

United States Tax Court

Decided January 24, 2002No. 14096-99Published

R determined that P was liable as a transferee of assets from C and, therefore, was liable for C's tax liabilities. P was the 100-percent owner and president of C. The transfer to P was from a settlement that P, C, and C's subsidiaries had reached with a creditor.

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R determined that P was liable as a transferee of assets from C and, therefore, was liable for C's tax liabilities. P was the 100-percent owner and president of C. The transfer to P was from a settlement that P, C, and C's subsidiaries had reached with a creditor. P contends that the portion he received was in consideration of his releasing a claim of his own against the creditor for damages to business reputation, so that, in effect, there was no transfer from C. R contends that the settlement belonged to the corporate entities and that P was a transferee. If it is decided that the transfer…

1Opinion of the Court

LARRY D. JOHNSON, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Johnson v. Comm'r

No. 14096-99

United States Tax Court

118 T.C. 74; 2002 U.S. Tax Ct. LEXIS 4; 118 T.C. No. 4;

January 24, 2002, Filed

Decision will be entered for petitioner.

R determined that P was liable as a transferee of assets

from C and, therefore, was liable for C's tax liabilities. P was

the 100-percent owner and president of C. The transfer to P was

from a settlement that P, C, and C's subsidiaries had reached

with a creditor. P contends that the portion he received was in

consideration of his releasing a…

2Cases cited9 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. William S. Hagaman, Bonnie C. Hagaman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
  3. Gumm v. CommissionerUnited States Tax Court · 1989
  4. Morgan (Carol) v. Barsky (Marvin J.)Court of Appeals for the Ninth Circuit · 1991
  5. Hagaman v. CommissionerUnited States Tax Court · 1993

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