- 9 - value of the shares as estimated by the IRS. The parties have since stipulated that the value of the shares on the date of the transfer was $53,828.12. OPINION We must decide whether petitioner may be held liable as a transferee for unpaid taxes of Mr. Espinosa, from whom she received assets worth $53,828.12. I. General Rules A. Transferee Liability Section 6901, which establishes a procedure whereby respondent may assess and collect from a transferee of property the unpaid taxes of the transferor, reads in part as follows: 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), * * * * * * * The foregoing section thus does not create or define a substantive liability; rather, it merely provides a remedy forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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