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02/03/92 Lucious Little T1908443 7,500.00
02/03/92 Sandra Clary T1908444 7,500.00
03/13/92 Rodger Fisher T1908860 9,516.22
Total $40,016.22
Respondent contends that petitioners retained $14,457.97
($54,474.19 less $40,016.22) from the checks received from Mr.
Fisher.
Subsequent Transfers by Petitioners
Petitioners made the following payments by check or
cashier's checks during 1992:7
Date Payee Check No. Amount
08/05/92 Roosevelt Randolph 3517 $3,500
08/05/92 Thomas Brown 3518 3,500
08/11/92 Rodger Fisher 3521 2,500
08/11/92 Ameritrust Co. 570 4,500
National Association
10/14/92 Thomas Brown 3622 3,500
10/14/92 Roosevelt Randolph 3623 3,500
Total $21,000
OPINION
Section 6901(a) provides a procedure whereby taxes owed by a
transferor may be collected from a transferee. Commissioner v.
7Petitioners contend that payments to Mr. Fisher, and to
others on his behalf, should be considered in determining their
liability as transferees. In their brief, petitioners contend
that the total amount retransferred to Mr. Fisher and his
designees was $17,500 and refer to the exhibit reflecting the six
checks totaling $21,000.
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