[DOWNLOAD] "John Ownbey Co. v. Commissioner of Internal Revenue" by Sixth Circuit. United States Court Of Appeals * Book PDF Kindle ePub Free

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eBook details

• Title: John Ownbey Co. v. Commissioner of Internal Revenue
• Author : Sixth Circuit. United States Court Of Appeals
• Release Date : January 02, 1981
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 72 KB

Description

John Ownbey Company (Ownbey), a Tennessee corporation, appeals to this court from a decision of the United States Tax Court holding it liable under the transferee provisions of the 1954 Internal Revenue Code (26 U.S.C. 6901) in the amount of $26,983.43, plus interest, for the unpaid 1968 income taxes of International Textile Products, Inc. (International), its wholly owned subsidiary. The Commissioner, by notice of deficiency dated June 13, 1974, originally determined that Ownbey was liable as a transferee in the amount of $41,046.46. This amount represented losses Ownbey had sustained in a contract with the Santone Manufacturing Company (Santone) but which International had absorbed. Ownbey petitioned the Tax Court for a redetermination of the liability assessed by the Commissioner. The Tax Court agreed with the Commissioner that Ownbey, not International was a party to the Santone contract, that International had, in effect, absorbed $41,046 of Ownbeys losses on the contract, and that the losses absorbed by International constituted transfers from International to Ownbey without fair consideration. The Tax Court held, however, that Ownbey was liable as a transferee for only $26,983.43, which represents the amount the Tax Court determined was "transferred" while International was insolvent or which left International insolvent.

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