In a recent Tax Court case, the court addressed the concept of pre-notice interest in the transferee liability context. In a prior opinion, the Tax Court held that the petitioner was a “transferee” of ...

The text of the UVTA and and other useful information about it may be found here. All opinions, errors and omissions are strictly my own. If the transaction is voidable, then the next step is to ...

State law is applied to determine whether a transferee is liable for a transferor’s tax liability. The Tax Court held that four trusts were not required to pay their former personal holding company’s ...

The Ninth Circuit vacated and remanded a Tax Court decision that held that shareholders were not liable as transferees under Sec. 6901 for tax liabilities arising from a sale of all company assets ...