Legal Opinion

Schussel v. Comm'r

United States Tax Court

Decided October 5, 2017No. Docket No. 30639-15Published

P petitioned the Court for redetermination of his liability as a transferee under I.R.C. sec. 6901(a), but now moves that we dismiss his petition with prejudice.

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P petitioned the Court for redetermination of his liability as a transferee under I.R.C. sec. 6901(a), but now moves that we dismiss his petition with prejudice. Held: Because a taxpayer's liability as a transferee is "assessed, paid, and collected in the same manner and subject to the same provisions and limitations" as a deficiency in tax, sec. 6901(a), a dismissal of a petition for redetermination of transferee liability, just like a dismissal of a petition for redetermination of a deficiency, for any reason other than lack of jurisdiction requires that we enter a decision as to the amount…

1Opinion of the Court

GEORGE SCHUSSEL, TRANSFEREE OF DRIFTWOOD MASSACHUSETTS BUSINESS TRUST, f.k.a. DIGITAL CONSULTING, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Schussel v. Comm'r

Docket No. 30639-15

United States Tax Court

2017 U.S. Tax Ct. LEXIS 50; 149 T.C. No. 16;

October 5, 2017, Filed

An appropriate order will be issued.

P petitioned the Court for redetermination of his liability as a transferee under I.R.C. sec. 6901(a), but now moves that we dismiss his petition with prejudice.

Held: Because a taxpayer's liability as a transferee is "assessed, paid, and collected in the same manner and…

2Cases cited11 opinions

  1. Reta L. McCants as Administratrix of the Estate of Johnny L. McCants Deceased v. Ford Motor Company, Inc.Court of Appeals for the Eleventh Circuit · 1986
  2. Looper v. CommissionerUnited States Tax Court · 1980
  3. Estate of Ming v. CommissionerUnited States Tax Court · 1974
  4. VETRANO v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  5. Kellogg v. CommissionerUnited States Tax Court · 1987

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