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BRESSON v. C.I.R.

No. 98-71377.

213 F.3d 1173 (2000)

Peter J. BRESSON (Transferee), Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 31, 2000.

Attorney(s) appearing for the Case

Willard D. Horwich, Beverly Hills, California, for the petitioner-appellant.

John A. Dudeck, Jr., Tax Division, United States Department of Justice, Washington, D.C., for the respondent-appellee.

Before: TASHIMA and GRABER, Circuit Judges, and STOTLER, District Judge.

STOTLER, District Judge:

I.

SUMMARY

This case involves efforts by the Internal Revenue Service (IRS) to collect taxes owed by Petitioner's corporation directly from Petitioner. The taxes arose in connection with the corporation's transfer of real property to Petitioner and Petitioner's subsequent sale of that property to an unrelated third party. The IRS's right to assess taxes directly against Petitioner derives

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