T.C. Memo. 1999-284
UNITED STATES TAX COURT
ESTATE OF FLORENCE H. DEVIDA JOHNSON, DECEASED,
RICHARD B. PERLMAN, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20477-96. Filed August 27, 1999.
Richard B. Perlman, for petitioner.
Robert W. Dillard, for respondent.
MEMORANDUM OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. See Rule 122. Respondent determined that
Florence H. DeVida Johnson (Ms. Johnson) is personally liable as
a fiduciary for disbursements she made while acting as personal
representative of the estate of Samuel C. Johnson III (Mr.
Johnson). Respondent issued a notice of liability to the Estate
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