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FRANK SAWYER TRUST OF MAY 1992 v. COMMISSIONER OF INTERNAL REVENUE

No. 5526-07.

133 T.C. No. 3

FRANK SAWYER TRUST OF MAY 1992, TRANSFEREE, CAROL S. PARKS, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court

Filed August 24, 2009.

Attorney(s) appearing for the Case

David R. Andelman and Juliette Galacia Pico, for petitioner.

Kevin G. Croke, for respondent.

OPINION

GOEKE, Judge:

This case is before the Court on the trust's motion for summary judgment filed pursuant to Rule 121.1 Respondent has asserted transferee liability against the trust. The trust argues in its motion papers that the doctrines of res judicata and collateral estoppel bar this transferee liability action. The trust argues that the issue of whether the trust is liable for the unpaid tax liabilities at issue was...

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