CHC Industries, Inc., (2011)

Docket Number: 19627-06

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CHC Industries, Inc., (2011)

T.C. Memo. 2011-33

UNITED STATES TAX COURT CHC INDUSTRIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19627-06. Filed February 2, 2011.

Thomas H. Moreland and Philip R. Weingold, for petitioner. John R. Mikalchus, for respondent.

MEMORANDUM OPINION VASQUEZ, Judge: Respondent determined that petitioner is liable for $275,800, plus interest as provided by law, as a transferee of St. Augustine II, Inc. (St. Augustine), in respect of a deficiency in St. Augustine's Federal income tax for 2000.

The issue for decision is whether petitioner is liable as a transferee of property of St. Augustine under section 6901.1

Background The parties submitted this case fully stipulated under Rule 122. The stipulations of facts and the attached exhibits are incorporated herein by this reference. Petitioner's principal place of business was in New York at the time the petition was filed.

Petitioner was incorporated on May 24, 2000. At all times relevant hereto, Nancy Caldarola (Ms. Caldarola) was petitioner's president and sole shareholder. In 1997, a few years before incorporating petitioner, Ms. Caldarola entered into business discussions with Jef...

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