Steinle v. Commissioner
United States Board of Tax Appeals
1. TRANSFEREES. - Certain of the petitioners, stockholders of the taxpayer corporation, not being shown by the proof to have received assets of the taxpayer directly or indirectly, it is held that they have no liability at law or in equity as transferees for an unpaid tax of the taxpayer. 2. Id. - Where the taxpayer, a corporation, purchases tangible assets from one of its officers and stockholders for a cash consideration and there is no evidence that the transaction was…
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1. TRANSFEREES. - Certain of the petitioners, stockholders of the taxpayer corporation, not being shown by the proof to have received assets of the taxpayer directly or indirectly, it is held that they have no liability at law or in equity as transferees for an unpaid tax of the taxpayer. 2. Id. - Where the taxpayer, a corporation, purchases tangible assets from one of its officers and stockholders for a cash consideration and there is no evidence that the transaction was one made in bad faith or with intent to defraud creditors, or that it rendered the taxpayer corporation insolvent, it is…
1Opinion of the Court
*331OPINION.
Trussell:
In respect to the first issue — that section 280 of the Revenue Act of 1926, under which respondent proposes to assess these several alleged liabilities, is unconstitutional, the Board has held that where, as in the present case, the petitioners have invoked that section, to secure a redetermination, they may not question its validity. Henry Cappellini, 14 B. T. A. 1269.
The second issue — that the time provided by the statute for assessment and collection expired prior to the determination and notice by respondent of the amounts proposed for assessment, was not urged by…
2Cases cited22 opinions
- Hollins v. Brierfield Coal & Iron Co.Supreme Court of the United States · 1893
- Briggs v. SpauldingSupreme Court of the United States · 1891
- Graham v. Railroad Co.Supreme Court of the United States · 1880
- Jackson v. LudelingSupreme Court of the United States · 1874
- Bosworth v. . AllenNew York Court of Appeals · 1901
17 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Segura v. CommissionerUnited States Tax Court · 1981
- Burdick v. CommissionerUnited States Board of Tax Appeals · 1931
- Coca-Cola Bottling Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Rauh v. CommissionerUnited States Board of Tax Appeals · 1931
- Segura v. CommissionerUnited States Tax Court · 1981
2 more not listed; retrieve them via the Exa API.