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STARNES v. C.I.R.

Nos. 11-1636, 11-1706, 11-1712, 11-1714.

680 F.3d 417 (2012)

Albert J. STARNES, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. Estate of Sallie C. Stroupe, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. Anthony S. Naples, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. Ronald D. Morelli, Sr., Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: May 31, 2012.

Attorney(s) appearing for the Case

ARGUED: Francesca Ugolini Tamami , United States Department of Justice, Washington, D.C., for Appellant. Robert Leon Widener , McNair Law Firm, PA, Columbia, South Carolina, for Appellees. ON BRIEF: Tamara W. Ashford , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Kenneth L. Greene , United States Department of Justice, Washington, D.C., for Appellant.

Affirmed by published opinion. Judge DAVIS wrote the opinion, in which Judge NIEMEYER joined. Judge WYNN wrote a dissenting opinion.

OPINION

DAVIS, Circuit Judge:

In Commissioner v. Stern, 357 U.S. 39, 78 S.Ct. 1047, 2 L.Ed.2d 1126 (1958), the Supreme Court held that if a person is the "transferee" of a taxpayer's assets, the "existence and extent" of that transferee's liability for unpaid taxes the taxpayer owed prior to the transfer is determined by state law, not federal law. Id. at 45, 78 S.Ct. 1047. This case requires that we apply

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