SELLERS v. C. I. R.

No. 78-1263.

592 F.2d 227 (1979)

Frank E. SELLERS, Transferee of the Assets of Norpaco Builders, Inc., Transferor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided February 15, 1979.


Attorney(s) appearing for the Case

Frank E. Sellers, pro se.

Stanley S. Shaw, Jr., Atty., Tax Div., Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Grant W. Wiprud, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief), for appellee.

Before HAYNSWORTH, Chief Judge, WINTER, Circuit Judge, and JACK R. MILLER, Judge, United States Court of Customs and Patent Appeals, sitting by designation.


MILLER, Judge:

This is an appeal from the decision of the United States Tax Court entered November 30, 1977 (opinion dated March 21, 1977, ¶ 77,070 P-H Memo TC) that appellant is liable, as a transferee, for deficiencies in income taxes and additions to tax under Sections 6651(a) and 6653(a),1 of Norpaco Builders, Inc. (hereinafter "Norpaco") for calendar years 1965 and 1966 totaling $1,643...

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