FELDMAN v. C.I.R.

Nos. 12-3144, 12-3145, 12-3146, 12-3147, 12-3148, 12-3149, 12-3150, 12-3807.

779 F.3d 448 (2015)

Ray FELDMAN, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 24, 2015.


Attorney(s) appearing for the Case

Robert E. Dallman , Attorney, Daniel B. Geraghty , Attorney, Thomas R. Vance , Attorney, Whyte Hirschboeck Dudek S.C., Milwaukee, WI, for Petitioners-Appellants.

Francesca Ugolini , Attorney, Kenneth L. Greene , Attorney, Department of Justice, Washington, DC, for Respondent-Appellee.

Before MANION, KANNE, and SYKES, Circuit Judges.


This appeal raises a question of transferee liability under 26 U.S.C. § 6901 for a dissolved corporation's unpaid federal taxes. The "transferees" are the former shareholders of a closely held Wisconsin corporation that for many decades owned and operated a dude ranch in the northwestern part of the state. When the ranch...

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