105 T.C. No. 24
UNITED STATES TAX COURT
HARVEY M. PERT, TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
KATHLEEN M. PERT, F.K.A. KATHLEEN M. RIFFE, TRANSFEREE,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 13783-94, 13784-94. Filed November 15, 1995.
Kathleen M. Pert signed closing agreements (Forms
866) pursuant to sec. 7121 I.R.C., for tax years 1986,
1988, and 1989 for both herself and as personal
representative of the estate of her deceased husband,
Timothy C. Riffe. Respondent accepted the closing
agreements.
Timothy Riffe and Kathleen Pert filed joint
returns for those years. Under the closing agreements,
Timothy Riffe, deceased, is liable for the addition to
tax for fraud for 1986 and Kathleen Pert is not.
Kathleen Pert signed a settlement stipulation for
1987 on her own behalf and as personal representative
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