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MAYORS v. C.I.R.

No. 85-7080.

785 F.2d 757 (1986)

Susan J. MAYORS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 24, 1986.

Attorney(s) appearing for the Case

Nicholas De Pento, San Diego, Cal., for petitioner-appellant.

Glenn Archer, Michael Paup, Richard Farber, Thomas R. Lamons, Washington, D.C., for respondent-appellee.

Before ANDERSON, PREGERSON and WIGGINS, Circuit Judges.

WIGGINS, Circuit Judge:

Appellant Susan J. Mayors ("Mayors") appeals the Tax Court's holding that she is liable under 26 U.S.C. § 6901(a) as a transferee of assets for the unpaid tax liability of Dr. Joseph A. Averna. We reverse.

FACTS AND PROCEEDINGS BELOW

Mayors began working in the office of podiatrist Dr. Joseph A. Averna ("Averna") as a secretary and receptionist in 1971. Mayors and Averna became emotionally involved and began living together...

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