(plaintiff's corporation (plaintiff was sole shareholder) went out of business in 1998 and was dissolved administratively in 2005; IRS assessed corporate taxes for tax years 1994-1996 and received Tax Court judgment; by the time judgment received, corporation not in existence and IRS sought to collect corporate tax liability from plaintiff; corporation had made distributions to plaintiff from 1995 to 2002 of over $3.6 million during time it was winding up operations; court determined that plaintiff liable for tax as "transferee of corporate assets; court indicates that outcome likely different if corporation liquidated without having made distributions to plaintiff).
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