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transferee liability against petitioner under section 6901.
Conclusion
In conclusion, we hold that section 6901(c) is the applicable
limitations period to which respondent is bound in asserting
transferee liability against petitioner for the unpaid taxes of
Jaussaud Enterprises. For purposes of petitioner's transferee
liability under section 6901, California's limitations period does
not control. As a result, we hold that respondent timely issued
the notice of transferee liability and has established petitioner's
liability as a transferee.
To reflect the foregoing,
Decision will be entered
for respondent.
Reviewed by the Court.
COHEN, CHABOT, SWIFT, GERBER, PARR, WELLS, RUWE, COLVIN,
CHIECHI, LARO, GALE, and MARVEL, JJ., agree with this majority
opinion.
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