Buckrey v. Comm'r
United States Tax Court
Ps were the sole owners of a corporation (C). C partially redeemed Ps' shares for its liquid noncash assets and then sold all its operating assets, which generated a large tax liability.
Read the full summary
Ps were the sole owners of a corporation (C). C partially redeemed Ps' shares for its liquid noncash assets and then sold all its operating assets, which generated a large tax liability. Ps entered into a Midco transaction with (M), whereby C transferred its cash to M and a subsidiary of M (S) purchased Ps' shares of C. R was unable to collect C's large tax liability from M or S and decided to hold Ps liable as transferees of C. R sent Ps notices of liability, arguing that the entire series of transactions lacked economic substance. Ps assert that they are not liable under Minnesota…
1Opinion of the Court
DONALD J. BUCKREY, TRANSFEREE, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Buckrey v. Comm'r
Docket Nos. 15620-09, 16566-09, 16567-09.
United States Tax Court
T.C. Memo 2017-138; 2017 Tax Ct. Memo LEXIS 138; 114 T.C.M. (CCH) 45;
July 11, 2017, Filed
Appropriate orders will be issued.
Ps were the sole owners of a corporation (C). C partially redeemed Ps' shares for its liquid noncash assets and then sold all its operating assets, which generated a large tax liability. Ps entered into a Midco transaction with (M), whereby C transferred its cash to M and a subsidiary of M (S)…
2Cases cited46 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Bonded Financial Services, Inc., Debtor-Appellant v. European American BankCourt of Appeals for the Seventh Circuit · 1988
41 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Sandra K. Shockley v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2017
- Alta V Limited Partnership, Transferee v. CommissionerUnited States Tax Court · 2020
- BMO Harris Bank N.A. v. KuskieDistrict Court, D. Minnesota · 2023
- Dillon Trust Company LLC v. United StatesCourt of Appeals for the Federal Circuit · 2026