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Discussion
I. Introduction
As stated, we must determine whether petitioner is liable
for the amount of respondent’s claim as a transferee of property
of Steven.
Section 6901 addresses the liability of a transferee of
property (transferee) for certain taxes, including income taxes,
of the transferor of such property (transferor). Pertinent
provisions of section 6901 are set forth in the margin.2
2 SEC. 6901. TRANSFERRED ASSETS.
(a) Method of Collection. The amounts of the following
liabilities shall, except as hereinafter in this
section provided, be assessed, paid, and collected in
the same manner and subject to the same provisions and
limitations as in the case of the taxes with respect to
which the liabilities were incurred:
(1) Income, Estate, and Gift Taxes.--
(A) Transferees. The liability, at law or
in equity, of a transferee of property --
(i) of a taxpayer in the case of a
tax imposed by subtitle A (relating
to income taxes),
* * * * * * *
(b) Liability.--Any liability referred to in
subsection (a) may be either as to the amount of tax
shown on a return or as to any deficiency or
underpayment of any tax.
* * * * * * *
(continued...)
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