Borg v. Commissioner
United States Tax Court
From 1967 to 1978, petitioner advanced to her son and his wholly owned corporation sums of money which were used in part to purchase business real property. Petitioner hoped to be repaid according to her so's ability to do so. Prior to receiving a notice of termination assessment, petitioner's son and his corporation conveyed property to petitioner purportedly as repayment.
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From 1967 to 1978, petitioner advanced to her son and his wholly owned corporation sums of money which were used in part to purchase business real property. Petitioner hoped to be repaid according to her so's ability to do so. Prior to receiving a notice of termination assessment, petitioner's son and his corporation conveyed property to petitioner purportedly as repayment. Held, petitioner is liable as a transferee to the extent of the net equity in the property transferred by her son individually to petitioner. Held further, petitioner is not liable as transferee for property transferred by…
1Opinion of the Court
EILEEN BORG, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Borg v. Commissioner
Docket No. 217-81.
United States Tax Court
T.C. Memo 1987-596; 1987 Tax Ct. Memo LEXIS 595; 54 T.C.M. (CCH) 1243; T.C.M. (RIA) 87596;
December 3, 1987.
From 1967 to 1978, petitioner advanced to her son and his wholly owned corporation sums of money which were used in part to purchase business real property. Petitioner hoped to be repaid according to her so's ability to do so. Prior to receiving a notice of termination assessment, petitioner's son and his corporation conveyed property to…
2Cases cited27 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. SternSupreme Court of the United States · 1958
- Dania Jai-Alai Palace, Inc. v. SykesSupreme Court of Florida · 1984
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
22 more not listed; retrieve them via the Exa API.
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- LeBeauUnited States Tax Court · 1992
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