Court of Appeals for the Ninth Circuit March 24, 1986, 85-7080 (Susan J. Mayors v. Commissioner of Internal Revenue)

WIGGINS, Circuit Judge:

Appellant Susan J. Mayors (“Mayors”) appeals the Tax Court’s holding that she is liable under 26 U.S.C. § 6901(a) as a transferee of assets for the unpaid tax liability of Dr. Joseph A. Averna. We reverse.

FACTS AND PROCEEDINGS BELOW

Mayors began working in the office of podiatrist Dr. Joseph A. Averna (“Averna”) as a secretary and receptionist in 1971.