One of the great features of corporations is that liability in the corporation generally does not extend to its shareholders, including tax liability. Like any rule, though, there is almost always an ...

Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax ...

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 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 ...

Billy Hawk died in 2000 leaving his wife and estate with the stock in Billy's bowling alley, called Holiday Bowl. To avoid the taxes on the sale of Holiday Bowl, a business broker introduced the ...

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 ...

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 a recent federal district court case, the beneficiaries of a decedent's revocable trust and individual retirement account were held to be personally liable for more than $3 million in unpaid estate ...

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 ...

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