T.C. Memo. 1999-292
UNITED STATES TAX COURT
MARK J. HANNA, P.C., TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10705-97. Filed September 1, 1999.
Charles F. Daily, Jr., for petitioner.
Bruce M. Wilpon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: Respondent determined that petitioner, as
transferee of assets, is liable for $25,297 plus interest for the
transferor's Federal income tax deficiency for the year 1993.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
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