transferee liability


Transferee Liable for $13 Million in Pre-Judgment Interest

There are times when our tax laws draw distinctions that can seem unfair. The Tricarichi v. Commissioner, T.C. Memo. 2016-132, highlights one of these situations. Tricarichi is a transferee liability case in which the taxpayer was held liable for $13 million in interest on a tax liability owed by a third party even though the […]

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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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