Estate of Nicholas Charles Stevens, Jr., Deceased, Kim Patricia Bryan, Personal Representative - Page 6

                                        - 5 -                                         
          817-818 (1977), affd. 41 AFTR 2d 78-328, 78-1 USTC par. 9153 (2d            
          Cir. 1977).  We sustain respondent’s determination that decedent            
          was taxable on unreported interest income of $7,435 from                    
          custodial accounts in 2000.                                                 
               Ms. Bryan nevertheless contends that a deceased person                 
          should not be liable for any tax deficiencies.  “Death may be an            
          avenue of escape from many of the woes of life, but it is no                
          escape from taxes.”  Estate of Kahr v. Commissioner, 414 F.2d               
          621, 626 (2d Cir. 1969) (cited by United States v. Critzer, 498             
          F.2d 1160, 1163 (4th Cir. 1974)), affg. in part and revg. in part           
          48 T.C. 929 (1967).                                                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                             for respondent with respect to           
                                             the deficiency and for                   
                                             petitioner with respect to the           
                                             addition to tax under section            
                                             6651(a)(1).                              



               4(...continued)                                                        
          Trusts sec. 13-314(b) (2001).  In the alternative, a custodian              
          may deliver or pay to the minor, without a court order, so much             
          of the custodial property as the custodian considers advisable              
          for the use and benefit of the minor.  See id. sec. 13-314(a).              





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