Opinion
6631-10
02-07-2022
JAMES C. SLONE, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Albert G. Lauber Judge.
This case involves the assertion by the Internal Revenue Service (IRS or respondent) of transferee liability against petitioner under I.R.C. § 6901(a). On July 24, 2018, the U.S. Court of Appeals for the Ninth Circuit held that petitioner is liable for the transferor corporation's tax obligations and accordingly remanded the case "for entry of judgment in favor of the Commissioner." Slone v. Commissioner, 896 F.3d 1083, 1088 (9th Cir. 2018), rev'g and remanding T.C. Memo. 2016-155.
In February 2019 this Court directed that decision would be entered under Tax Court Rule 155, and the parties subsequently submitted differing computations. On February 7, 2022, the Court filed its Supplemental Memorandum Opinion (T.C. Memo. 2022-6), which states at the end thereof that "Decision[] will be entered in accordance with respondent's computations." In consideration of the foregoing, it is
ORDERED AND DECIDED that there is a liability in the amount of $13,012,395.67, plus interest thereon as provided by law from December 22, 2009, to the date such liability is paid, due from petitioner as transferee of assets of Arizona Media Holdings, Inc., transferor, for unpaid income tax and penalty, for the taxable year ended June 30, 2002.