Legal Opinion

Dillman v. Commissioner

United States Tax Court

Decided August 5, 1975No. Docket Nos. 3587-74, 3594-74Published

Rule 121, Tax Court Rules of Practice and Procedure. -- Held: Wis. Stat. Ann. sec. 180.787 providing for survival of remedies for and against dissolved corporations and their stockholders for a period of 2 years after dissolution does not limit the liability of stockholders as transferees of corporate assets.

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Rule 121, Tax Court Rules of Practice and Procedure. -- Held: Wis. Stat. Ann. sec. 180.787 providing for survival of remedies for and against dissolved corporations and their stockholders for a period of 2 years after dissolution does not limit the liability of stockholders as transferees of corporate assets. Notices of transferee liability issued to stockholder-transferees more than 4 years after dissolution of corporation but within 1 year after the expiration of period of limitation for assessment of tax against the transferor corporation are timely under sec. 6901, I.R.C. 1954.…

1Opinion of the Court

Bruce Dillman, Petitioner v. Commissioner of Internal Revenue, Respondent; Blair Dillman, Petitioner v. Commissioner of Internal Revenue, Respondent

Dillman v. Commissioner

Docket Nos. 3587-74, 3594-74

United States Tax Court

64 T.C. 797; 1975 U.S. Tax Ct. LEXIS 92;

August 5, 1975, Filed

Rule 121, Tax Court Rules of Practice and Procedure. -- Held: Wis. Stat. Ann. sec. 180.787 providing for survival of remedies for and against dissolved corporations and their stockholders for a period of 2 years after dissolution does not limit the liability of stockholders as transferees of corporate assets.…

2Cases cited23 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. United States v. SummerlinSupreme Court of the United States · 1940
  3. Campbell v. HoltSupreme Court of the United States · 1885
  4. Commissioner v. SternSupreme Court of the United States · 1958
  5. Joseph P. Lucia v. United States of AmericaCourt of Appeals for the Fifth Circuit · 1973

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