When a business entity is struggling to pay tax debts or other obligations, and someone proposes the transfer of its assets to a new entity owned by the same or related owners, one may ask whether the prior entity's obligations will be enforceable against the new one. The potential for enforcement of a transferor's tax obligations against its transferee is demonstrated by ACI Construction, LLC v. United States, 130 AFTR 2d 2022-5882, a recent decision of the U.S. District Court for the District of Utah.