- 14 - recourse liability (or portion thereof) shall be treated as having been assumed if * * * the transferee has agreed to, and is expected to, satisfy such liability (or portion), whether or not the transferor has been relieved of such liability”. Id. sec. 3001(b), 113 Stat. 182. The 1999 amendment does not apply to these cases, because the transactions in these cases occurred in 1993. Even if section 357(d)(1)(A) as enacted in 1999 did apply, petitioners’ personal liability on the debt that was transferred to the corporation would continues to be irrelevant. Even after congressional amendments to section 357, Congress has refrained from providing relief to taxpayers in petitioners’ situation. We conclude that under section 357 petitioners must recognize a gain on the transfer of assets to Seggerman Farms. To reflect the foregoing and concessions of the parties, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011