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whether petitioner is liable as a transferee of property pursuant
to section 6901.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When the petition was filed, petitioner’s principal place of
business was in Fort Washington, Pennsylvania.
Background
On July 1, 1971, Self Oil Heat, Inc. (Self Oil), was
organized pursuant to the laws of Pennsylvania to engage in,
inter alia, the business of selling fuel oil. Self Oil elected
to be treated for tax purposes as an S corporation until that
election was revoked on or about April 12, 1996. From the date
of its incorporation until the date it ceased operations, Robert
N. Self, Sr., was Self Oil’s president, sole shareholder, and
sole director. For part of 1991 and 1992, Robert N. Self, Jr.,
was Self Oil’s secretary and treasurer.2
During 1993, Self Oil and its officers became the subject of
a joint criminal investigation conducted by Federal and State
authorities to determine whether Self Oil, among others, had paid
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the the Tax Court Rules of Practice
and Procedure.
2Mr. Self, Sr., is the father of Mr. Self, Jr., and Jonathan
Self. Mr. Self, Sr., testified that both of his sons were former
employees of Self Oil.
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