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R.G. COPE, JR., INC. v. C.I.R.

No. 84-7785.

781 F.2d 852 (1986)

R.G. COPE, JR., INC., Alleged Transferee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

Rehearing Denied March 17, 1986.

Attorney(s) appearing for the Case

Berry, Ables, Tatum, Little & Baxter, P.C., Thomas E. Parker, Jr., Huntsville, Ala., for petitioner-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Michael L. Paup, William S. Estabrook, Nancy G. Morgan, Washington, D.C., for respondent-appellee.

Before TJOFLAT and KRAVITCH, Circuit Judges and DUMBAULD, Senior District Judge.

DUMBAULD, Senior District Judge:

This is an appeal from the Tax Court which decided that appellant, R.G. Cope, Jr., Inc. (a corporation of which R.G. Cope, Jr. is president and principal stockholder) is liable as transferee under 26 U.S.C. 6901 for tax liabilities of R.G. Cope's parents, Robert G. Cope, Sr. (Hereinafter sometimes called "father") and of Allene D. Cope ("mother"). The tax years involved are 1972-1975. They did not file returns for 1974 and 1975. The...

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