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SELF HEATING AND COOLING INC. v. COMMISSIONER

Docket No. 3267-02.

87 T.C.M. 1163 (2004)

T.C. Memo. 2004-85

Self Heating and Cooling, Inc., Transferee v. Commissioner.

United States Tax Court.

Filed March 24, 2004.

Attorney(s) appearing for the Case

Barry A. Furman, for the petitioner.

Gerald A. Thorpe, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

In a notice of transferee liability dated September 28, 2001, respondent determined that petitioner was liable as a transferee for the 1996 income tax liability of Self Oil Heat, Inc., in the amount of $119,689.71, plus interest provided by law. The only issue presented by the parties is whether petitioner is liable as a transferee of property pursuant to section 6901.1

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