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property (citing United States v. Cartwright, 411 U.S. 546, 551
(1973))).
Petitioners contend that their liability should be reduced
because they allegedly paid $538,883 of Metro’s liabilities after
Metro’s BFI stock was distributed to them. Petitioners’
testimony, however, was devoid of any particulars relating to the
allegedly paid expenses. In addition, petitioners have not
established that the allegedly paid liabilities had priority over
respondent’s claim relating to tax liabilities. See Hutton v.
Commissioner, 59 F.2d 66 (9th Cir. 1932), affg. 21 B.T.A. 101
(1930); Gobins v. Commissioner, 18 T.C. 1159, 1174 (1952), affd.
per curiam 217 F.2d 952 (9th Cir. 1954). Accordingly, we reject
petitioners’ contention. McGraw contends that his transferee
liability should be reduced because Butler, in his 1995 criminal
plea, agreed to pay Butler’s and Metro’s tax liabilities. Each
transferee, however, is liable to the extent he received property
without adequate consideration. Phillips v. Commissioner, 283
U.S. at 603; Scott v. Commissioner, supra. McGraw also contends
respondent did not take reasonable steps to collect the tax
liability from Metro. We reject this contention also. Metro was
dissolved in 1991. The Commissioner is not required to proceed
against a dissolved corporation before asserting transferee
liability against its stockholders. Maher v. Commissioner, 469
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