Hine v. Commissioner
United States Tax Court
Held: 1. Petitioner is liable as transferee for income tax in the amount of $ 17,802.68 plus interest owed by the corporation of which he was the sole stockholder at the time he received as a liquidating distribution assets of a value in excess of the tax plus interest of the corporation, which were all its assets which had not been previously transferred to another corporation, even though the other corporation had agreed to assume liability for the tax, and the tax had…
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Held: 1. Petitioner is liable as transferee for income tax in the amount of $ 17,802.68 plus interest owed by the corporation of which he was the sole stockholder at the time he received as a liquidating distribution assets of a value in excess of the tax plus interest of the corporation, which were all its assets which had not been previously transferred to another corporation, even though the other corporation had agreed to assume liability for the tax, and the tax had been satisfied by a tentative carryback credit later determined to be erroneous, causing the unpaid assessment to be…
1Opinion of the Court
Francis L. Hine, as Transferee of Colonial Boat Works, Inc., Transferor, Petitioner v. Commissioner of Internal Revenue, Respondent
Hine v. Commissioner
Docket No. 3719-64
United States Tax Court
54 T.C. 1552; 1970 U.S. Tax Ct. LEXIS 86;
July 30, 1970, Filed
Decision will be entered under Rule 50.
Held: 1. Petitioner is liable as transferee for income tax in the amount of $ 17,802.68 plus interest owed by the corporation of which he was the sole stockholder at the time he received as a liquidating distribution assets of a value in excess of the tax plus interest of the corporation, which were all…
2Cases cited18 opinions
- Segal v. RochelleSupreme Court of the United States · 1966
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
- Leach v. CommissionerUnited States Tax Court · 1953
- Coca-Cola Bottling Co. v. CommissionerUnited States Tax Court · 1962
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