Sole Shareholder Receiving Distributions from Liquidating Corporation Personally Liable for Dissolved Corporation's Tax Liabilities

The sole shareholder of a dissolved corporation was liable as a transferee for the corporation's tax deficiency. The distributions received by the shareholder were part of a corporate liquidation that could be claimed by a creditor under state (Colorado) law. Since the shareholder received the assets in the liquidation of his company, he was personally liable for the corporation's tax liabilities regardless of whether the distribution was made at a time that the corporation could pay its debts. The shareholder's argument that state law applied only to assets distributed after dissolution was rejected because it would allow the shareholder to avoid corporate debts by delaying dissolution until distribution of all the assets. Moreover, the corporation's accountant testified that the corporation intended to liquidate when the sale and disposition of the corporation's assets took place.