Gerosa v. Commissioner
Cases that cite this one
2 later published cases cite this decision.
- Paulus v. Commissioner (United States Board of Tax Appeals 1934)
- Paulus v. Commissioner (United States Board of Tax Appeals 1934)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
*2233 Stockholders who, at the time of dissolution of a corporation, received all of its net assets are liable as transferees for a deficiency determined against the corporation.
*1234 OPINION.
STERNHAGEN: The respondent determined that there was a liability of each of these petitioners of $5,762.49 as transferees of the assets of the Metropolitan Roofing Material Co., Inc., against which a deficiency of the same amount in income and profits tax for 1920 had been determined. Upon motion of petitioners, the hearings were consolidated. At the hearing, a contention by petitioners that the transferor taxpayer was not liable on the merits for the deficiency was abandoned because petitioners were without evidence to support it. A motion was made by petitioners for judgment because the liability had lapsed by limitation, and this motion was denied. The respondent's determination of a deficiency of $5,762.49 is therefore *1235 affirmed. The only issue remaining for decision is whether these petitioners are liable as transferees for the deficiency*2234 of the corporation.
They are individuals who were at the time of the dissolution of the Metropolitan Roofing Material Co. on or about March 31, 1921, its sole and equal shareholders, to whom were transferred all of the corporation's net assets of $30,888.38. They are, therefore, liable for the corporation's deficiency. ; ; ; .
Case-law data current through December 31, 2025. Source: CourtListener bulk data.