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.
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