Legal Opinion

Espinosa v. Commissioner

United States Tax Court

Decided March 1, 2000No. 20338-97Unpublished

In July of 1990, P's husband, T, transferred to her for no consideration shares of stock with a value of $ 53,828.12. Prior to that time, T had failed to file Federal income tax returns or to pay such taxes for years including 1981, 1982, 1984, and 1985. T subsequently filed returns for the foregoing years in November of 1993. On July 17, 1997, without having sent a notice of deficiency to T based upon the filed returns but after previous attempts to collect from T had…

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In July of 1990, P's husband, T, transferred to her for no consideration shares of stock with a value of $ 53,828.12. Prior to that time, T had failed to file Federal income tax returns or to pay such taxes for years including 1981, 1982, 1984, and 1985. T subsequently filed returns for the foregoing years in November of 1993. On July 17, 1997, without having sent a notice of deficiency to T based upon the filed returns but after previous attempts to collect from T had yielded insufficient funds to satisfy his tax debts, R issued to P a notice of transferee liability pursuant to sec. 6901,…

1Opinion of the Court

LAURA A. LOVELAND ESPINOSA, A.K.A. LAURA A. LOVELAND, TRUSTEE OF THE LAURA A. LOVELAND TRUST, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Espinosa v. Commissioner

No. 20338-97

United States Tax Court

T.C. Memo 2000-66; 2000 Tax Ct. Memo LEXIS 73; 79 T.C.M. (CCH) 1574;

March 1, 2000, Filed

Decision will be entered under Rule 155.

In July of 1990, P's husband, T, transferred to her for no

consideration shares of stock with a value of $ 53,828.12. Prior

to that time, T had failed to file Federal income tax returns or

to pay such taxes for years including 1981, 1982, 1984, and

1985…

2Cases cited16 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Stein v. CommissionerUnited States Tax Court · 1962
  3. Coca-Cola Bottling Co. v. CommissionerUnited States Tax Court · 1962
  4. Coca-Cola Bottling Company of Tucson, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
  5. Gumm v. CommissionerUnited States Tax Court · 1989

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