Laura A. Loveland Espinosa - Page 3




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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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