Legal Opinion

Stansbury v. Commissioner

United States Tax Court

Decided April 18, 1995No. Docket Nos. 7025-92, 7026-92Published

Ps were officers and 100-percent owners of ABC corporation. After ABC agreed to the assessment and collection of taxes and additions to tax owed by ABC, but prior to payment thereof, all of ABC's remaining assets were transferred to Ps, and ABC was dissolved.

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Ps were officers and 100-percent owners of ABC corporation. After ABC agreed to the assessment and collection of taxes and additions to tax owed by ABC, but prior to payment thereof, all of ABC's remaining assets were transferred to Ps, and ABC was dissolved. Ps agree that they are liable as transferees to the extent of the value of the assets received from ABC and that they are liable for interest under sec. 6601, I.R.C., from the date they received notices of transferee liability. Ps argue, however, that they are not liable, under either Federal or State law, for interest prior to the date…

1Opinion of the Court

Doris E. Stansbury, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent; Leland D. Stansbury, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent

Stansbury v. Commissioner

Docket Nos. 7025-92, 7026-92

United States Tax Court

104 T.C. 486; 1995 U.S. Tax Ct. LEXIS 24; 104 T.C. No. 24;

April 18, 1995, Filed

Decisions will be entered under Rule 155.

Ps were officers and 100-percent owners of ABC corporation. After ABC agreed to the assessment and collection of taxes and additions to tax owed by ABC, but prior to payment thereof, all of ABC's remaining assets were…

2Cases cited26 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Fish v. EastCourt of Appeals for the Tenth Circuit · 1940
  5. Mesa Sand & Gravel Co. v. Landfill, Inc.Supreme Court of Colorado · 1989

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