Johnson v. Comm'r
United States Tax Court
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
- Commissioner v. SternSupreme Court of the United States · 1958
- William S. Hagaman, Bonnie C. Hagaman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Gumm v. CommissionerUnited States Tax Court · 1989
- Morgan (Carol) v. Barsky (Marvin J.)Court of Appeals for the Ninth Circuit · 1991
- Hagaman v. CommissionerUnited States Tax Court · 1993
4 more not listed; retrieve them via the Exa API.