Hine v. Commissioner
United States Tax Court
Held: 1. Petitioner is liable as transferee for income tax in the amount of $ 17,802.68 plus interest owed by the corporation of which he was the sole stockholder at the time he received as a liquidating distribution assets of a value in excess of the tax plus interest of the corporation, which were all its assets which had not been previously transferred to another corporation, even though the other corporation had agreed to assume liability for the tax, and the tax had…
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Held: 1. Petitioner is liable as transferee for income tax in the amount of $ 17,802.68 plus interest owed by the corporation of which he was the sole stockholder at the time he received as a liquidating distribution assets of a value in excess of the tax plus interest of the corporation, which were all its assets which had not been previously transferred to another corporation, even though the other corporation had agreed to assume liability for the tax, and the tax had been satisfied by a tentative carryback credit later determined to be erroneous, causing the unpaid assessment to be…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined that petitioner was liable as transferee for deficiencies in Colonial Boat Works, Inc.’s Federal income tax for the fiscal years ending September 30, 1957, 1958, and 1959, in the amounts of $40,398.94, $35,670.58, and $35,802.68, respectively, plus interest as provided by law.
The issues for decision are:(1) Whether petitioner is liable as transferee for the $17,802.68 in Federal income tax of Colonial Boat Works, Inc., for its fiscal year ended September 30, 1959, unpaid at the time of distribution of that corporation’s assets to petitioner in…
2Cases cited18 opinions
- Segal v. RochelleSupreme Court of the United States · 1966
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
- Leach v. CommissionerUnited States Tax Court · 1953
- Coca-Cola Bottling Co. v. CommissionerUnited States Tax Court · 1962
13 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Pesch v. CommissionerUnited States Tax Court · 1982
- Alexander v. CommissionerUnited States Tax Court · 1973
- United States v. Oil Resources, Inc.Court of Appeals for the Ninth Circuit · 1987
- United States v. Oil Resources, Inc.Court of Appeals for the Ninth Circuit · 1987
- D'Agostino v. CommissionerUnited States Tax Court · 1973
5 more not listed; retrieve them via the Exa API.