Hagaman v. Commissioner
United States Tax Court
Taxpayer-transferor transferred to petitioner-transferee property valued, at the times of the respective transfers, at $ 263,000. Collection efforts against taxpayer-transferor have been, and will likely continue to be, futile. Respondent has therefore sought to collect from petitioner-transferee as a transferee, pursuant to sec. 6901, I.R.C.
Read the full summary
Taxpayer-transferor transferred to petitioner-transferee property valued, at the times of the respective transfers, at $ 263,000. Collection efforts against taxpayer-transferor have been, and will likely continue to be, futile. Respondent has therefore sought to collect from petitioner-transferee as a transferee, pursuant to sec. 6901, I.R.C. Held: Respondent need not demonstrate that transferor was insolvent at the time of, or immediately after, the transfers at issue, unless such showing is required by applicable State law. Held, further, respondent has demonstrated that, under applicable…
1Opinion of the Court
Halpern, Judge:
By order of dismissal and decision entered February 18, 1993, in docket No. 747-85, this Court ordered and decided that there are deficiencies in and additions to William S. Hagaman’s (Hagaman or the taxpayer) Federal income taxes as follows:
Year Deficiency Addition to tax sec. 6653(b)
$184,453 $92,226.50 1975
177,449 88.724.50 1976
64,800 31,063.00 1977
140,937 70.468.50 1978
Those amounts remain unpaid. The sole issue for decision is whether petitioner is liable as a transferee of Hagaman for $263,000 (the amount transferred) plus interest thereon.1
Unless otherwise indicated, all…
2Cases cited25 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Gobins v. Comm'rUnited States Tax Court · 1952
- William S. Hagaman, Bonnie C. Hagaman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Updike v. United StatesCourt of Appeals for the Eighth Circuit · 1925
20 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Peter J. Bresson (Transferee),petitioner-Appellant v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Starnes v. Comm'rUnited States Tax Court · 2011
- Bresson v. CommissionerUnited States Tax Court · 1998
- Slone v. Comm'rUnited States Tax Court · 2012
- Stansbury v. CommissionerUnited States Tax Court · 1995
30 more not listed; retrieve them via the Exa API.