THE TRANSFEREE OF A DELINQUENT TAXPAYER

Section 280 of the Revenue Act of 1926 provides, among other things, that "the liability, at law or in equity, of a transferee" of any delinquent income, excess profits; or war profits taxpayer shall be enforced in the same manner as the liability of a delinquent income taxpayer under the Revenue Act of 1926. It is the purpose of this article to describe the liability of a transferee at law or in equity, and how it was enforced, at the time of the enactment of section 280, having reference to both federal and state decisions.