Alonso v. Commissioner
United States Tax Court
As of Apr. 3, 1973, petitioner's husband was liable to the Federal Government for substantial amounts of income taxes, additions to tax, and interest. On that day, he transferred four parcels of real estate he owned in fee simple to a strawman who reconveyed the parcels to petitioner's husband and petitioner as tenants by the entirety. Such transfer rendered the husband insolvent under North Carolina law.
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As of Apr. 3, 1973, petitioner's husband was liable to the Federal Government for substantial amounts of income taxes, additions to tax, and interest. On that day, he transferred four parcels of real estate he owned in fee simple to a strawman who reconveyed the parcels to petitioner's husband and petitioner as tenants by the entirety. Such transfer rendered the husband insolvent under North Carolina law. On June 28, 1975, the husband died and the four parcels passed to petitioner in fee simple. Held, petitioner is liable as a transferee of the assets of her husband within the meaning of sec.…
1Opinion of the Court
Ann T. Alonso, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent
Alonso v. Commissioner
Docket No. 7874-78
United States Tax Court
78 T.C. 577; 1982 U.S. Tax Ct. LEXIS 112; 78 T.C. No. 40;
April 12, 1982, Filed
Decision will be entered for the respondent.
As of Apr. 3, 1973, petitioner's husband was liable to the Federal Government for substantial amounts of income taxes, additions to tax, and interest. On that day, he transferred four parcels of real estate he owned in fee simple to a strawman who reconveyed the parcels to petitioner's husband and petitioner as tenants by the…
2Cases cited17 opinions
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- United States v. BessSupreme Court of the United States · 1958
- Commissioner v. SternSupreme Court of the United States · 1958
- United States v. Gilbert Associates, Inc.Supreme Court of the United States · 1953
- Gobins v. Comm'rUnited States Tax Court · 1952
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