id	author	title	date	pages	extension	mime	words	sentences	flesch	summary	cache	txt
work_rogs2kmh7rhn5nsfjx2xm4oc6e	Dana L. Mark	DIEBOLD and the Not so Beautiful: Transferee Liability Trumps Tax Shelter	2014	11	.pdf	application/pdf	3351	174	59	finding transferee liability under Section 69012, here specifically under New York law, as C corporation's shareholders had transferee liability under New York law with respect to the tax liability recognized by the C corporation on the sale of its assets. C corporation's assets, and the second tax at the shareholder level, when the sale "Midco") at a purchase price that does not discount for the built-in gain tax liability as recharacterization of the transaction as sales by Double-D of its assets to the buyers shareholders, Diebold New York and the Marital Trust. The IRS asserted transferee liability against Diebold New York as well as against determination of transferee liability, both the Tax Court and Second Circuit found that avoid tax liability and that it would leave Double-D without assets with which to satisfy Second Circuit remanded to the Tax Court the issue of whether Diebold New York is a 	./cache/work_rogs2kmh7rhn5nsfjx2xm4oc6e.pdf	./txt/work_rogs2kmh7rhn5nsfjx2xm4oc6e.txt