19 iability for tax and additions to tax should be computed based on that stipulation.1 C. Whether Petitioner Is Liable as a Successor Transferee of Stanko Packing 1. Fraudulent Conveyances Under Nebraska Law Respondent claims that the transfer of the Packerland note to petitioner is void as to respondent, an existing creditor, under sections 36-604 and 36-607 of the Revised Statutes of Nebraska (Neb. Rev. Stat. secs. 36-604, 36-607 (reissue 1988)) (as in effect at the time of the transfer). Respondent argues that petitioner is a successor transferee because she received property from Rudy Stanko without consideration, who received property from Stanko Packing without consideration, and Stanko Packing was left without assets to pay its 1985 income tax liability. Sec. 6901(h).2 1 At the end of the trial, petitioner requested an opportunity to submit additional evidence at a later date. The Court granted petitioner's request. The parties later agreed that no further trial was necessary. 2Sec. 6901(h) provides: SEC. 6901(h). Definition of Transferee.--As used in this section, the term "transferee" includes donee, heir, legatee, devisee, and distributee, and with respect to estate taxes, also includes any person who, under section 6324(a)(2), is personally liable for any part of such tax.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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