- 2 -
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue for decision is whether petitioner is liable as a
transferee under the Texas Uniform Fraudulent Transfer Act, Tex.
Bus. & Com. Code Ann. secs. 24.001 to 24.012 (West 1987 & Supp.
1999), for $25,297 relating to the transferor's Federal income
tax deficiency.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
In 1990, Mark J. Hanna (Hanna) organized Hanna & Associates,
P.C. (Associates PC), through which to conduct a law practice in
the State of Texas. Also in 1990, Hanna filed for personal
bankruptcy.
During 1991, 1992, and 1993, due to Hanna's poor credit
rating, Associates PC experienced financial difficulties.
Associates PC could not obtain loans to lease additional office
space, acquire office equipment, or expand the law practice.
In January of 1994, in an effort to improve his law
practice, Hanna entered into discussions with Charles F.
Daily, Jr. (Daily), another Texas lawyer, to combine their
respective law practices.1
1 Daily is petitioner's lawyer herein.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011