Self Heating and Cooling, Inc., Transferee - Page 10

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                         1The record does not disclose on what date                   
                    this payment was made.                                            
               On or about April 15, 1997, Self Oil filed Form 1120-S, U.S.           
          Income Tax Return for an S Corporation, for the period January 1            
          through April 12, 1996, reporting ordinary income of $26,634.               
          On or about August 18, 1997, Self Oil filed Form 1120, U.S.                 
          Corporation Income Tax Return, for the period April 13 through              
          December 31, 1996, reporting a tax liability of $123,060.  On               
          September 28, 2001, respondent issued a notice of liability to              
          petitioner asserting that it was liable as a transferee of Self             
          Oil’s assets for Self Oil’s unpaid income tax liability for the             
          taxable year ended December 31, 1996, for $119,689.71.                      
                                       OPINION                                        
               Section 6901 provides a procedural mechanism for collecting            
          unpaid tax from transferees of property in certain circumstances.           
          Hagaman v. Commissioner, 100 T.C. 180 (1993); see Phillips v.               
          Commissioner, 283 U.S. 589 (1931) (relating to the predecessor of           
          section 6901).  Section 6901 provides in pertinent part:                    
               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.--                        








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