Alta V Limited Partnership v. Commissioner T.C. Memo. 2020-8
On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed deficiency, penalties, and additions to tax with respect to the transferor’s corporate income tax. Transferee Liability Under the Code – IRC § 6901(a) – Alta