Cullifer v. Comm'r
United States Tax Court
R issued a notice of transferee liability to P to collect N's unpaid Federal income tax pursuant to I.R.C. sec. 6901. R argues that under Texas State law: (1) P has transferee liability with respect to a special dividend that N distributed to P and (2) P has transferee-of-transferee liability with respect to P's proceeds from his sale of N stock.
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R issued a notice of transferee liability to P to collect N's unpaid Federal income tax pursuant to I.R.C. sec. 6901. R argues that under Texas State law: (1) P has transferee liability with respect to a special dividend that N distributed to P and (2) P has transferee-of-transferee liability with respect to P's proceeds from his sale of N stock. Held: P is a transferee under Federal law principles pursuant to I.R.C. sec. 6901. Held, further, under Texas State law, P has transferee liability with respect to the special dividend. Held, further, under Texas State law, P has…
1Opinion of the Court
RICHARD H. CULLIFER, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cullifer v. Comm'r
Docket No. 20177-11
United States Tax Court
T.C. Memo 2014-208; 2014 Tax Ct. Memo LEXIS 204; 108 T.C.M. (CCH) 408;
October 7, 2014, Filed
Decision will be entered under Rule 155.
R issued a notice of transferee liability to P to collect N's unpaid Federal income tax pursuant to I.R.C. sec. 6901. R argues that under Texas State law: (1) P has transferee liability with respect to a special dividend that N distributed to P and (2) P has transferee-of-transferee liability with respect to P's…
2Cases cited61 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Commissioner v. SternSupreme Court of the United States · 1958
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