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 ...

In a matter of first impression, the Ninth Circuit held that, in considering whether to regard a transaction under the first part of the Stern test, a court “must consider the relevant subjective and ...

Sellers of corporate stock have long been concerned about whether and under what circumstances they may be held liable for unpaid federal income tax liabilities of the corporation for the tax year ...

In U.S. v. Park, Case No. 16C10787, the U.S. District Court for the Northern District of Illinois concluded that the government failed to adequately plead claims for fraudulent transfer and transferee ...

The Tax Court held that three trusts that sold shares of stock in a corporation were not liable as transferees for the corporation’s unpaid federal income tax liability incurred before its dissolution ...

Under some circumstances, sellers of stock of a corporation may be liable as transferees for corporate obligations arising before or in connection with the closing. In 'Dillon Trust Co. v. United ...