United States First Circuit

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Schussel v. Werfel, 13-1717

The decision of the United States Tax Court holding petitioner liable, as the recipient of a fraudulent transfer from his former company, for the company's back taxes of over $4.9 million, plus interest of at least $8.7 million, is: 1) reversed in part and remanded, where the tax court calculated prejudgment interest under the wrong statute, which should have been determined in accord with Massachusetts law, and under Massachusetts law, no interest would have begun to accrue until the date of the Notice of Liability; but 2) affirmed in part, where petitioner's loans to his former company to pay petitioner's litigation expenses did not reduce the net amount transferred to him.

Appellate Information

  • Decided 07/08/2014
  • Published 07/08/2014




  • United States First Circuit