Sharp v. Commissioner
United States Tax Court
Held, that petitioner is liable as a transferee of assets of her husband, W. C. Sharp, within the meaning of section 311(a)(1) of the 1939 Code, to the extent of certain moneys of his which she received in 1952 and 1953, in amounts herein determined. Held, further, that respondent has not borne his burden of proof to establish that petitioner is liable as such transferee, in respect of certain deposits made in her personal account in the year 1956.
1Opinion of the Court
PieRce, Judge:
The respondent determined liability against the petitioner as transferee of assets of her husband, W. C. Sharp, in the amomit of $48,003.35. Said liability was in respect of unpaid income taxes and additions to tax owing by said husband for the years 1934 through 1949.
The issue for decision is whether petitioner is liable as such a transferee in said amount of $48,003.35.
findings of fact.
Facts re General Background.
Some of the facts were stipulated. The stipulation of facts, together with the exhibits identified therein and attached thereto, is incorporated herein by reference.
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2Cases cited10 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Gobins v. Comm'rUnited States Tax Court · 1952
- Gobins v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- Bartmer Automatic Self Service Laundry, Inc. v. CommissionerUnited States Tax Court · 1960
- McKnight v. CommissionerUnited States Tax Court · 1947
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3Cited by13 opinions
- Yagoda v. CommissionerUnited States Tax Court · 1962
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- Borg v. CommissionerUnited States Tax Court · 1987
- Eyler v. CommissionerUnited States Tax Court · 1983
- Zadorkin v. CommissionerUnited States Tax Court · 1985
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