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'sPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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