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United States Tax Court, 1953

A. G. E. Mills Corp. v. Commissioner

A. G. E. Mills Corp. v. Commissioner
United States Tax Court · Decided June 29, 1953
12 T.C.M. 722; 1953 Tax Ct. Memo LEXIS 191
A. G. E. Mills Corp. v. Commissioner

Opinion

A. G. E. Mills Corporation v. Commissioner.
A. G. E. Mills Corp. v. Commissioner
Docket No. 38988.
United States Tax Court
1953 Tax Ct. Memo LEXIS 191; 12 T.C.M. (CCH) 722; T.C.M. (RIA) 53227;
June 29, 1953
*191 Philip A. Brenner, Esq., for the petitioner. Joseph F. Lawless, Esq., for the respondent.
RAUM

Memorandum Opinion

RAUM, Judge: This is a transferee case in which the Commissioner has sought to charge the petitioner with income tax and 50 per cent penalty which he determined against Louis Swee, transferor, as follows:

Deficiency50 Per Cent
Kindper Statu-Penalty per
Yearof Taxtory NoticeStatutory Notice
1942Income$ 7,741.79$ 3,870.90
1943Income856.05428.03
1944Income119,687.8259,843.91
1945Income26,965.4213,842.71
1946Income4,268.362,134.18

The facts have been stipulated, and the transferor's liability for the amounts involved is conceded. The stipulation of facts includes the following paragraph:

On or about January 15, 1950, Louis Swee, transferor, transferred to petitioner, A. G. E. Mills Corporation, without consideration, cash in the amount of $237,594.65. As a result of said transfer Louis Swee became insolvent.

This case has arisen because some dispute or confusion has arisen as to the precise character of the transferee's liability. In view of the stipulation of facts, petitioner, *192 as transferee, is chargeable in full for the transferor's liability to the exent of $237,594.65 plus interest as provided by law.

An order will be entered in accordance herewith.

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