Dillman v. Commissioner
United States Tax Court
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
- Phillips v. CommissionerSupreme Court of the United States · 1931
- United States v. SummerlinSupreme Court of the United States · 1940
- Campbell v. HoltSupreme Court of the United States · 1885
- Commissioner v. SternSupreme Court of the United States · 1958
- Joseph P. Lucia v. United States of AmericaCourt of Appeals for the Fifth Circuit · 1973
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