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the other donee, resulting in a gift tax deficiency
substantially in excess of $93,300.
1. Held, (a) since, pursuant to sec. 6503(a)(1),
I.R.C., the limitations period for assessment (as
extended) against the donor was suspended upon the
issuance of the notice of deficiency until the decision
of this Court became final and for 60 days thereafter,
and (b) since, pursuant to secs. 7481(a)(1) and 7483,
I.R.C., the decision became final upon the expiration
of the 90-day period without the filing of an appeal,
even though a stipulated decision, (c) the period of
limitations for assessment against the donor was
therefore extended 90 days plus 60 days, a total of 150
days, notwithstanding the donor's waiver of the sec.
6213(a), I.R.C., restrictions on assessment. (d)
Moreover, the 68 days that the period for assessment
was suspended by the issuance of the notice of
deficiency must be "tacked on" to the 150 days--a total
of 218 days from Feb. 28, 1992, or until Oct. 1, 1992.
(e) Accordingly, since, pursuant to sec. 6901(c),
I.R.C., the period for assessment against the initial
transferee extends for 1 year the period of limitations
for assessment against the transferor, the period of
assessment against Ps extended to Oct. 1, 1993. The
notices of transferee liability to Ps, issued on Sept.
17, 1993, were therefore timely.
2. Held further, the gift tax lien imposed by
sec. 6324(b), I.R.C., is not an encumbrance which
reduces the value of the gifts in Ps' hands, for which
they are liable as transferees.
G. Nelson Mackey, Jr., for petitioners.
Scott Anderson, for respondent.
OPINION
RAUM, Judge: Respondent issued notices of donee/transferee
liability to petitioners, each in the amount of $93,300. At
issue is: (1) Whether the period of limitations for assessment
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