Egan v. Commissioner
United States Tax Court
Res Judicata -- Transferee -- Sec. 534, I. R. C. 1954. -- A prior decision on the merits of the tax liability of the transferor for 1948 is res judicata, in its full impact of estoppel by judgment, of the liability of the transferee for those same taxes where the transferee admits its liability as transferee.
1Opinion of the Court
opinion.
Murdock, Judge:
The Commissioner mailed a notice to the petitioner that he had determined a deficiency of $88,286.78 in income tax and interest for 1948 against Egan, Inc., and that the deficiency, plus interest, “will be assessed against you * * * constituting your liability as transferees of assets of said Egan, Inc.” The petitioner filed the present petition, the Commissioner filed an answer, and the petitioner filed a reply. The matter is now before the Court on the Commissioner’s motion for judgment on the pleadings. The parties were heard on that motion and have filed briefs in…
2Cases cited5 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
- Egan, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
3Cited by16 opinions
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Krueger v. CommissionerUnited States Tax Court · 1967
- Gabriel J. Baptiste, Jr., Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- Randolph v. CommissionerUnited States Tax Court · 1980
- Estate of Henry G. Egan, Transferee, Northwestern National Bank v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
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