Valuations Bolster IRS’s Transferee Liability Claim

Business Valuation UpdateVol. 21 No. 1
Legal and Court Case Update
January 2015

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4226 Special Warehousing and Storage, NEC
493110 General Warehousing and Storage
federal taxation
expert testimony, intangible assets, personal goodwill, constructive fraud, internal revenue code (IRC), tangible assets, asset sale, capital gains, stock enhancement sale, transferee liability
Cullifer v. Commissioner
2014 Tax Ct. Memo LEXIS 204
October 7, 2014
US
Federal Court
Federal
United States Tax Court
S. Todd Burchett (petitioner); Francis Burns, Steven Hastings (respondent/IRS)
Laro

Summary

In transferee liability case, Tax Court finds IRS proved petitioner was liable for causing company’s fraudulent asset transfers and benefitted from intermediary company’s fraudulent transfer; valuations showed company was insolvent at time of transfers.

See Also

Cullifer v. Commissioner

Full Text of Court Cases
October 7, 2014

In transferee liability case, Tax Court finds IRS proved petitioner was liable for causing company’s fraudulent asset transfers and benefitted from intermediary company’s fraudulent transfer; valuations showed company was insolvent at time of transfers.