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