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SCHUSSEL v. WERFEL

No. 13-1717.

758 F.3d 82 (2014)

George SCHUSSEL, Transferee, Petitioner, Appellant, v. Daniel I. WERFEL, Acting Commissioner of the Internal Revenue Service, Respondent, Appellee.

United States Court of Appeals, First Circuit.

July 8, 2014.

Attorney(s) appearing for the Case

Francis J. DiMento , with whom Jason A. Kosow and DiMento & Sullivan were on brief, for appellant.

Regina S. Moriarty , Tax Division, Department of Justice, with whom Richard Farber , Attorney, Tax Division, Department of Justice, and Kathryn Keneally , Assistant Attorney General, were on brief, for appellee.

Before THOMPSON, STAHL, and KAYATTA, Circuit Judges.

KAYATTA, Circuit Judge.

George Schussel appeals a decision of the United States Tax Court holding him liable, as the recipient of a fraudulent transfer from his former company, for the company's back taxes (including penalties) of over $4.9 million, plus interest of at least $8.7 million. On appeal, he does not dispute that his company fraudulently transferred millions of dollars to him in an effort to avoid paying income...

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