Jean A. Stanko - Page 19

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          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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