IRS collections
Ski Condo Held in Revocable Trust Not Subject to Federal Tax Lien
In U.S. v. Kimball, No. 2:14-CV-521-DBH, the U.S. District Court in Maine held that a federal tax lien did not attach to a ski condo held in trust even though the trust was a revocable trust and the taxpayer had access to the condo and he paid the expenses for the condo with his personal […]
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Stock Sale Triggers Transferee Liability for Buyer’s Tax Liability
In Marshall v. Commissioner, T.C. Memo. 2016-119, the U.S. Tax Court concluded that business owners who sold their stock was liable for the buyer’s Federal income taxes that arose after the sale. The facts and procedural history are as follows: The taxpayers owned Marshall Associated Contractors, Inc. (MAC), which was subject to tax as a […]
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Unperfected Loan Trumped IRS Lien
The IRS has broad collection powers. It is always interesting to see cases where other creditors are able to collect despite the IRS’s collection powers. The U.S. v. Heptner, Case No. 8:15-cv-1125-T-33MAP case provides an example. In Heptner the U.S. District Court in Tampa concluded that a loan from the taxpayer’s former employer trumped the […]
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