Frank Sawyer Trust of May 1992 v. Comm'r
United States Tax Court
P owned the stock of four corporations: TT, CT, St. Botolph, and Sixty-Five Bedford. The four corporations held assets with high fair market values and low adjusted bases. During 2000 and 2001 the corporations sold their assets, leaving the corporations with large cash reserves and facing large contingent tax liabilities.
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P owned the stock of four corporations: TT, CT, St. Botolph, and Sixty-Five Bedford. The four corporations held assets with high fair market values and low adjusted bases. During 2000 and 2001 the corporations sold their assets, leaving the corporations with large cash reserves and facing large contingent tax liabilities. Shortly after the respective asset sales, P sold its stock in the corporations to F. F, after purchasing the stock, transferred assets with inflated bases to the corporations. The corporations then sold these assets, generating losses. The losses were used to offset the…
1Opinion of the Court
OPINION
GOEKE, Judge:
This case is before the Court on the trust’s motion for summary judgment filed pursuant to Rule 121.1 Respondent has asserted transferee liability against the trust. The trust argues in its motion papers that the doctrines of res judicata and collateral estoppel bar this transferee liability action. The trust argues that the issue of whether the trust is liable for the unpaid tax liabilities at issue was decided in a prior deficiency action after respondent issued notices of deficiency to the trust. The parties agree that there are no material facts in dispute. For the…
2Cases cited35 opinions
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