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8.7.5.1
(11-06-2007)
Introduction to Working Transferee Cases in Appeals
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IRC 6901 provides a transferee liability against a recipient (transferee) of property from the transferor, for the tax liability
of the transferor and is a tool used to collect a taxpayer’s tax liability. A transferor is the person or entity who created the tax liability and transferred assets to another party. The transferee is the person or entity who is additionally liable for the tax (because they received the transferred assets for less than
full, fair and adequate consideration).
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The government can assess another taxpayer’s (transferor’s) liability against a transferee to collect this tax liability based
on some other provision of state or federal law. The liabilities include taxes, penalties and interest to the date of transfer.
It also includes additional liabilities resulting from an examination.
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Appeals considers and processes transferee cases in much the same manner as other cases. The administrative file of a transferee
case must contain the tax returns of the transferor with a revenue agent's report.
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Use current transcripts to confirm the liability was assessed against either the transferor or one or more transferees.
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