United States Fourth Circuit

In a case in which former shareholders of a company filed petitions in the United States Tax Court contesting notices of transferee liability, the Tax Court's ruling in favor of the former shareholders is affirmed, where: 1) the Tax Court properly identified and applied the controlling legal framework for transferee liability as set forth in Commissioner v. Stern, 357 U.S. 39 (1958); and 2) the Tax Court did not commit clear error in its factual findings.

Appellate Information

• Decided 05/31/2012
• Published 05/31/2012

Judges

• Davis

Court

• United States Fourth Circuit

Counsel

• For Appellant:
  
• Francesca Ugolini Tamami, Robert Leon Widener