May 14 2026
Fed. Cir. 24-1314 Panel Decision

Dillon Trust Company LLC v. United States

The United States Court of Appeals for the Federal Circuit affirmed a lower court ruling holding the Dillon Trust Company liable as a transferee for unpaid taxes owed by Humboldt Shelby Holding Corporation. The court found that the trusts had constructive knowledge of a fraudulent scheme designed to evade corporate income taxes through a collapsed stock and asset sale transaction.