T.C. Memo. 2004-85
UNITED STATES TAX COURT
SELF HEATING AND COOLING, INC., TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3267-02. Filed March 24, 2004.
Barry A. Furman, for petitioner.
Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: In a notice of transferee liability dated
September 28, 2001, respondent determined that petitioner was
liable as a transferee for the 1996 income tax liability of Self
Oil Heat, Inc., in the amount of $119,689.71, plus interest
provided by law. The only issue presented by the parties is
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