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amounts as of July 17, 1997, was calculated at $135,446, $97,109,
$19,476, and $21,900 for 1981, 1982, 1984, and 1985,
respectively.
For reasons hereinafter stated, Mr. Espinosa’s 1980 taxable
year is also involved in the present controversy. We consider
facts related to the 1980 year to the degree necessary to
evaluate petitioner’s liability with respect to the years before
the Court. See sec. 6214(b).
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the relevant
years, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions, the issues remaining for decision are:
(1) Whether assessment of transferee liability against
petitioner is barred by the period of limitations set forth in
section 3439.09 of the California Civil Code (West 1997); and, if
not,
(2) whether petitioner is liable as a transferee pursuant to
section 6901 for the unpaid Federal income taxes and additions to
tax of Mr. Espinosa.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference.
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