Bresson v. Commissioner
United States Tax Court
In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $ 329,000 to an unrelated third party. Petitioner kept the proceeds from the sale.
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In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $ 329,000 to an unrelated third party. Petitioner kept the proceeds from the sale. On Mar. 5, 1993, J filed a tax return for its fiscal year ended Feb. 28, 1991, reporting a capital gain of $ 194,705 from the sale of the Alhambra property and a tax due of $ 49,683, which was not paid. On Aug. 1, 1993, petitioner…
1Opinion of the Court
Jacobs, Judge:
By means of a notice of transferee liability dated August 2, 1996, respondent determined that petitioner is liable under section 6901 as a transferee of property from Jaussaud Enterprises, Inc. (hereinafter referred to as Jaussaud Enterprises or the corporation), for unpaid Federal corporate income taxes and additions to tax due from Jaussaud Enterprises, as follows:
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Unless indicated otherwise, all section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The disputed…
2Cases cited33 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- United States v. BessSupreme Court of the United States · 1958
- United States v. SummerlinSupreme Court of the United States · 1940
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3Cited by16 opinions
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