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Transferee Liability (Portfolio 628)

Product Code: TPOR41
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Transferee Liability, written by Theodore D. Peyser, Esq., of Roberts & Holland, analyzes the application of §6901 and related judicial interpretations. Beginning with a general discussion of transferee liability and its development from the so-called trust fund doctrine, the Portfolio distinguishes between transferee liability in equity and liability at law.  

The question as to whether the transferee is liable at law or equity for the tax of the transferor is governed by state law; however, questions as to the liability of the transferor are determined under the Internal Revenue Code. 

Section 6901 does not create a separate liability for the transferee; instead, it merely provides for a secondary method of enforcing the liability of the transferor. In any event, the liability of various classes of transferees are distinguishable. 

This Portfolio discusses the origin of the Internal Revenue Code provisions on Transferee Liability and provides an overview of Transferee Liability in general, its considerations, the requirements of transfer of property, and the liability of the transferor.  It also discusses retransfers, examines transferee liability in equity, and identifies the elements of transferee liability in equity based on a fraudulent transfer. 

In addition, this Portfolio 

  • Delves into the effect of discharges in bankruptcy, of transferor/taxpayer and transferees 
  • Reviews procedures for enforcing transferee liability 
  • Discusses the extent of transferee liability and transferee liability in equity 
  • Analyzes the §6901 assessment procedure and notice of liability and covers the statute of limitations 

Transferee Liability allows you to benefit from:

  • Hundreds of hours of original research on specific tax planning topics from leading practitioners in this area
  • Invaluable practice documents including tables, charts and lists
  • Plain-English guidance from world-class experts
  • Real-world and in-depth analysis that lets you explore various options
  • Time-saving access to relevant sections of tax laws, regulations, court cases, IRS documents and more
  • Alternative approaches to both common and unique tax scenarios 

This Portfolio is part of the U.S. Income Portfolios Library, a comprehensive series that includes more than 200 Portfolios, which covers every federal tax topic with expert, in-depth analysis, and offer commentary on a wide range of federal taxation topics, including Compensation Planning, Deductions and Credits, Partnerships and Corporations, Special Pass-Through Entities, Corporate Reorganizations, Real Estate, Procedure and Administration, and more. 

Detailed Analysis

I. Introduction - Secondary and Derivative Liability for Taxes

A. The Origin of the Internal Revenue Code Provisions on Transferee Liability

B. Transferee Liability for Federal Taxes Without Reference to § 6901

1. Fraudulent Transfer

a. State Law

b. Federal Law - FDCPA

2. Trust Fund Doctrine

3. The Concept of Nominee or Alter Ego

4. Corporate Successors

5. Employment Taxes

a. Liability of Responsible Persons

b. Third-Party Liability

6. Fiduciary Liability

II. Transferee Liability in General

A. General Considerations

B. Requirement of a Transfer of Property

C. Liability of the Transferor

D. Retransfers

III. Transferee Liability in Equity

A. In General

B. Elements of Transferee Liability in Equity Based on a Fraudulent Transfer

1. Insolvency of the Transferor

a. In General

b. Insolvency Through a Series of Transfers

c. Determination of Insolvency

(1) Tests for Determining Insolvency

(2) Measuring Assets and Liabilities

2. Exhaustion of Remedies Against the Transferor

3. Lack of Adequate Consideration

IV. Transferee Liability at Law

A. Contractual Liability

1. In General

2. Contractual Assumption of Tax Liability

B. Statutory Liability

C. Estate and Gift Taxes

V. Classes of Transferees

A. Transferee Defined

B. Beneficial User of Transferred Property

C. Sale and Purchase of Corporate Stock or Assets

1. Stockholder-Distributees

a. In General

b. Constructive Transfers

c. Liquidating Distributions

d. Acquisition of Stock

2. Sale of Stock

3. Purchase of Stock or Assets

4. Corporate Successors

D. Creditors and Borrowers

E. Fiduciaries

F. Heirs, Legatees and Devisees

G. Surviving Joint Tenants and Tenants by the Entirety

H. Life Insurance Beneficiaries

I. Pension Benefits

J. Partners and Partnerships

K. Transferee of Transferee

VI. The Extent of Transferee Liability

A. In General

B. Extent of Transferee Liability in Equity

C. Extent of Transferee Liability at Law

D. Liability for Penalties and Interest Earned on Transferred Assets

1. Liability for Interest Where Value of Assets Transferred Exceeds Deficiency of Transferor

2. Liability for Interest Where Value of Assets Transferred is Less Than Deficiency of Transferor

3. Interest That Accrues After Sending of Notice of Transferee Liability to Transferee

VII. Defenses Against Transferee Liability

VIII. Procedures for Enforcing Transferee Liability

A. Section 6901 Assessment Procedure

1. In General

2. Address for Notice of Liability

3. Statute of Limitations

a. In General

b. Statute of Limitations for Transferees

(1) Initial Transferee

(2) Transferee of Transferee

(3) Limitations Period Where Court Proceeding Began Against Last Preceding Transferee

(4) Extension of Limitations Period by Agreement

(5) Death or Dissolution of Transferor

(6) Extension or Suspension of Limitations Period

c. Effect of Request for Prompt Assessment

B. Suits Bought by Transferees

1. Tax Court Review

2. Refund Suits

3. Injunctions Against Collection of Transferee Liability

C. Suits by the IRS

1. Statute of Limitations

2. Burden of Proof

IX. Effect of a Discharge in Bankruptcy

A. Discharge of the Transferor/Taxpayer

B. Discharge of the Transferee

Working Papers

Table of Worksheets

Worksheet 1 Federal Debt Collection Act of 1990 [Title XXXVI of the Crime Control Act of 1990 (P.L. 101-647)]

Worksheet 2 Uniform Fraudulent Transfer Act

Worksheet 3 Revenue Act of 1926 (P.L. 20) - S. Rep. No. 52, 69th Cong., 1st Sess. 28-30

Worksheet 4 Revenue Act of 1926 (P.L. No. 20) - H.R. Rep. No. 356 (Conf.) 69th Cong., 1st Sess. 42-45

Worksheet 5 Crime Control Act of 1990 (P.L. 101-647) - H.R. Rep. No. 736, 101st Cong., 2d Sess. 1 [To Accompany H.R. 5640, the Federal Debt Collection Procedures Act of 1990]

Worksheet 6 Phillips v. Comr., 283 U.S. 589 (1931)

Worksheet 7 Comr. v. Stern, 357 U.S. 39 (1958)

Worksheet 8 U.S. v. Craft, 535 U.S. 274 (2002)

Worksheet 9 IRM Provisions Relating to Transferee and Fiduciary Liability - IRM 34.6.2, 35.2.2.4 and 35.2.2.7

Worksheet 10 IRM 5.17.14, Fraudulent Transfers and Transferee and Other Third Party Liability

Bibliography

OFFICIAL

Statutes:

Treasury Regulations:

Committee Reports:

Revenue Rulings:

Cases:

UNOFFICIAL

Periodicals:

1994

1995

1996

1997

2000

2001

2007

2008

2009

Theodore D. Peyser
Theodore D. Peyser, B.A., Princeton University (1950); LL.B., Yale Law School (1955); member, District of Columbia, Tax Court, Court of Federal Claims, Federal Circuit, and U.S. Supreme Court Bars; member, Court Procedure Committee, Tax Section, ABA; Tax Division, U.S. Department of Justice, trial attorney (1955-1973), chief, Claims Court Section (1974-1984), Special Litigation Counsel (1985-1987); author, 631-2nd T.M., Refund Litigation and 628-2nd T.M. Transferee Liability; co-author, 630-3rd T.M. Tax Court Litigation; contributor, Tax Practice Series.