Legal Opinion

Susan J. Mayors v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided March 24, 1986No. 85-7080PublishedCited by 45 opinions

1Opinion of the Court

WIGGINS, Circuit Judge:

Appellant Susan J. Mayors (“Mayors”) appeals the Tax Court’s holding that she is liable under 26 U.S.C. § 6901(a) as a transferee of assets for the unpaid tax liability of Dr. Joseph A. Averna. We reverse.

FACTS AND PROCEEDINGS BELOW

Mayors began working in the office of podiatrist Dr. Joseph A. Averna (“Averna”) as a secretary and receptionist in 1971. Mayors and Averna became emotionally involved and began living together, but did not marry. In June, 1973, Mayors gave birth to their daughter, Antoinette. In anticipation of the birth, Averna bought a resident at 1970…

2Cases cited12 opinions

  1. United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Marvin v. MarvinCalifornia Supreme Court · 1976
  5. Silver v. ShemanskiCalifornia Court of Appeal · 1949

7 more not listed; retrieve them via the Exa API.

3Cited by45 opinions

  1. Robert P. Wilcox v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
  2. Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  3. Professional & Executive Leasing, Inc., an Idaho Corporation, Petitioner v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  4. John A. Grimes v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  5. Gregory W. McKay v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989

40 more not listed; retrieve them via the Exa API.

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