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UNITED STATES v. HENCO HOLDING CORP.

No. 19-12758.

985 F.3d 1290 (2021)

UNITED STATES of America, Plaintiff-Appellant, v. HENCO HOLDING CORP., Alfredo Caceres, Luis Alfredo Caceres, Luis Angel Caceres, individually and as beneficiary of the Luis Angel Caceres Charitable Remainder Unitrust, Luis Angel Caceres Charitable Remainder Unitrust, Defendants-Appellees.

United States Court of Appeals, Eleventh Circuit.

January 19, 2021.

Attorney(s) appearing for the Case

Clint A. Carpenter , Arthur Thomas Catterall , U.S. Department of Justice Chief Appellate Section Tax Division, Washington, DC, U.S. Attorney Service Northern District of Georgia, U.S. Attorney's Office, Atlanta, GA, Thomas K. Vanaskie , Robert Scott Silverblatt , U.S. Department of Justice Tax Division, Washington, DC.

Jason S. Bell , Smith Gambrell & Russell, LLP, Atlanta, GA for Defendant-Appellee Henco Holding Corp.

Jason S. Bell , Sasha Nina Greenberg , Anthony J. Rollins , John Phillip Tyler , Smith Gambrell & Russell, LLP, Atlanta, GA, for Defendant-Appellee Atlanta, Ga, for Defendant-Appellee Luis Alfredo Caceres.

Before ROSENBAUM, LAGOA, and ANDERSON, Circuit Judges.

This appeal requires us to determine whether the government must separately assess a transferor's tax liabilities against a transferee under Internal Revenue Code ("I.R.C.") § 6901 in order to collect those tax liabilities from the transferee. The government appeals the district...

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