Peter J. Bresson - Page 19

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          6501, the period of limitations for assessments against a taxpayer          
          is 3 years from the filing of the tax return.)  Therefore, the              
          period of limitations for making an assessment against Jaussaud             
          Enterprises expired on March 5, 1996, and the Commissioner could            
          assess petitioner's transferee liability at any time up to March 5,         
          1997.  The notice of transferee liability to petitioner from                
          respondent was dated August 2, 1996.  Thus, pursuant to section             
          6901(c), respondent's notice of transferee liability to petitioner          
          was timely.                                                                 
               Section 3439.09 of the California Civil Code provides:                 
                    A cause of action with respect to a fraudulent                    
               transfer or obligation under this chapter is extinguished              
               * * *:                                                                 
                    (a) Under subdivision (a) of Section 3439.04,                     
               within four years after the transfer was made or the                   
               obligation was incurred or, if later, within one year                  
               after the transfer or obligation was or could reasonably               
               have been discovered by the claimant.                                  
                    (b) Under subdivision (b) of Section 3439.04 or                   
               Section 3439.05, within four years after the transfer was              
               made or the obligation was incurred.                                   
               Petitioner asserts that the UFTA limitations period applies,           
          rather than the limitations period under section 6901(c), and               
          therefore the period of limitations for assessment against                  
          petitioner expired prior to respondent's issuance of the notice of          
          transferee liability to petitioner.  Petitioner further claims that         
          even if respondent did not originally know of the transfer,                 
          respondent obtained such knowledge by September 1994, the date of           





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