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DILLMAN v. COMMISSIONER

Docket Nos. 3587-74, 3594-74.

64 T.C. 797 (1975)

BRUCE DILLMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. BLAIR DILLMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 5, 1975.

Attorney(s) appearing for the Case

V. Downing Edwards, for the petitioners.

F. Patrick Matthews, for the respondent.

OPINION

DRENNEN, Judge:

These cases have been consolidated for purposes of this opinion and are here on petitioners' Motions for Summary Judgment. The issue raised by the motions is whether Wisconsin Statutes Annotated section 180.787, which provides for survival of remedies against a corporation and its stockholders for a period of 2 years after dissolution of the corporation, bars issuance of valid notices of transferee liability and assessment...

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