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SEGURA v. COMMISSIONER

Docket Nos. 1178-79, 1272-79.

77 T.C. 734 (1981)

PERRY SEGURA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. PERRY SEGURA, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 30, 1981.

Attorney(s) appearing for the Case

D. Irvin Couvillion, for the petitioners.

Alan H. Kaufman, for the respondent.

FAY, Judge:

Respondent determined that petitioners, as transferees of assets, are liable for a deficiency of $64,227.70 in their transferor's Federal income taxes for the transferor's taxable years ending September 30, 1970, and September 30, 1971.1 The issues for decision are whether petitioners are transferees within the meaning of section 6901 and, if so, to what extent.2

FINDINGS OF FACT...

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