Peter J. Bresson - Page 1

                                   111 T.C. No. 6                                     

                               UNITED STATES TAX COURT                                

                     PETER J. BRESSON, TRANSFEREE, Petitioner v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22824-96.                  Filed August 19, 1998.           

                    In July 1990, J, a corporation, transferred to                    
               petitioner, its sole shareholder, real property situated               
               in California (the Alhambra property) without receiving                
               a reasonably equivalent value in exchange therefor.                    
               Immediately thereafter, petitioner sold the Alhambra                   
               property for $329,000 to an unrelated third party.                     
               Petitioner kept the proceeds from the sale.  On Mar. 5,                
               1993, J filed a tax return for its fiscal year ended Feb.              
               28, 1991, reporting a capital gain of $194,705 from the                
               sale of the Alhambra property and a tax due of $49,683,                
               which was not paid.  On Aug. 1, 1993, petitioner executed              
               a promissory note to J for repayment of a purported                    
               obligation owed by petitioner to J.                                    
                    On Aug. 2, 1996, respondent issued a notice of                    
               transferee liability to petitioner as a transferee under               
               sec. 6901, I.R.C.  Respondent determined, on the basis of              
               California's    Uniform   Fraudulent    Transfer Act                   
               (California's UFTA), that petitioner was liable for J's                

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