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FRANK SAWYER TRUST OF MAY 1992 v. C.I.R.

No. 12-1586.

712 F.3d 597 (2013)

FRANK SAWYER TRUST OF MAY 1992, Transferee; Carol S. Parks, Trustee, Petitioner, Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellant.

United States Court of Appeals, First Circuit.

March 29, 2013.

Attorney(s) appearing for the Case

Francesca U. Tamami , Tax Division, Department of Justice, with whom Gilbert S. Rothenberg , Kenneth L. Greene , Tax Division, Department of Justice, Kathryn Keneally , Assistant Attorney General, and Tamara W. Ashford , Deputy Assistant Attorney General, were on brief for appellant.

David R. Andelman with whom Juliette Galicia Pico and Lourie & Cutler, P.C. were on brief for appellee.

Before LYNCH, Chief Judge, BOUDIN and STAHL, Circuit Judges.

LYNCH, Chief Judge.

This case involves the Internal Revenue Service's efforts to collect taxes and penalties assessed upon four corporations. The corporations acknowledged that they owed the federal government more than $24 million in taxes and penalties, but before the Internal Revenue Service (IRS) could collect against the corporations, the corporations rendered themselves insolvent by transferring all of their assets...

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