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DELPIT v. COMMISSIONER

Docket Nos. 6379-87, 6388-87.

61 T.C.M. 2303 (1991)

T.C. Memo. 1991-147

Larry D. Delpit and Dorothy D. Delpit v. Commissioner.

United States Tax Court.

Filed April 2, 1991.

Attorney(s) appearing for the Case

Jerry W. Carlton, 610 Newport Center Drive, Newport Beach, Calif., and John F. Daum, for the petitioners. John Kent and Marlene Kristovich, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined that petitioners are liable as transferees under section 69011 for Kern Trading Company, Inc., and Kern County Refinery, Inc.'s tax liabilities.

Respondent determined a $151,338 deficiency plus additions to tax and interest pursuant to section 6653(a)(1) and (2), in Kern Trading Company Inc.'s income tax for taxable year ending March 31, 1981....

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