Legal Opinion
Feldman v. Commissioner
Court of Appeals for the Seventh Circuit
Decided February 24, 2015No. Nos. 12-3144, 12-3145, 12-3146, 12-3147, 12-3148, 12-3149, 12-3150, 12-3807PublishedCited by 20 opinions
1Opinion of the Court
SYKES, Circuit Judge.
This appeal raises a question of transferee liability under 26 U.S.C. § 6901 for a dissolved corporation’s unpaid federal taxes. The “transferees” are the former shareholders of a closely held Wisconsin corporation that for many decades owned and operated a dude ranch in the northwestern part of the state. When the ranch was sold, the shareholders planned to liq*450uidate, but the asset sale had produced a sizable gain and the corporation faced significant federal and state tax liability. A tax-shelter firm swooped in with a proposal for an intricate tax-avoidance transaction…
2Cases cited27 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. SternSupreme Court of the United States · 1958
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Mark A. Warsco, Trustee v. Preferred Technical GroupCourt of Appeals for the Seventh Circuit · 2001
22 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Summa Holdings v. Comm'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 2017
- Sandra K. Shockley v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2017
- Slone Revocable Trust v. CirCourt of Appeals for the Ninth Circuit · 2015
- Eric Onyango v. Nick & Howard, LLCCourt of Appeals for the Seventh Circuit · 2015
- Stuart v. CommissionerUnited States Tax Court · 2015
15 more not listed; retrieve them via the Exa API.