T.C. Memo. 2000-66
UNITED STATES TAX COURT
LAURA A. LOVELAND ESPINOSA, A.K.A. LAURA A. LOVELAND, TRUSTEE OF
THE LAURA A. LOVELAND TRUST, TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20338-97. Filed March 1, 2000.
In July of 1990, P’s husband, T, transferred to
her for no consideration shares of stock with a value
of $53,828.12. Prior to that time, T had failed to
file Federal income tax returns or to pay such taxes
for years including 1981, 1982, 1984, and 1985. T
subsequently filed returns for the foregoing years in
November of 1993. On July 17, 1997, without having
sent a notice of deficiency to T based upon the filed
returns but after previous attempts to collect from T
had yielded insufficient funds to satisfy his tax
debts, R issued to P a notice of transferee liability
pursuant to sec. 6901, I.R.C. R premises transferee
liability on the grounds that the transfer of stock
from T to P was a fraudulent conveyance under the
California Uniform Fraudulent Transfer Act, Cal. Civ.
Code secs. 3439 through 3439.12 (West 1997).
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