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agreements further extended the assessment period until April 18,
1990. The donor and the IRS were unable to resolve their
differences, and on February 9, 1990--68 days prior to the April
18, 1990 expiration of the extended assessment period--respondent
sent the donor a notice of gift tax deficiency in the amount of
$467,183. She timely filed a petition with this Court, and the
case was placed on the Court's docket. On February 25, 1992, a
stipulated decision was entered settling the donor's liability at
$239,124. The $93,300 value of the property transferred to
petitioners was not changed by this decision. Pursuant to the
decision, the donor waived the restrictions of section 6213(a),
which prohibits assessment and collection of the deficiency until
the decision of the Tax Court becomes final. (More hereinafter
about when the decision becomes "final".)
The Commissioner assessed the additional gift tax against
the donor on April 7, 1992. On September 17, 1993, a notice of
donee/transferee liability was issued to each petitioner for
$93,300 of the donor's unpaid gift taxes.2
2 The IRS also attempted to collect the gift taxes from
Joseph Ripley. On Sept. 2, 1993, the IRS mailed Joseph, as a
donee of Mildred Ripley, a notice of intention to levy listing
tax and interest due in the amount of $654,973.04. On Sept. 17,
1993, the Commissioner mailed to Joseph a notice of transferee
liability for the donor's unpaid gift tax in the amount of
$651,047.40. The IRS attempted to enforce its lien by serving
Joseph with notices of levy and notices of seizure for two
parcels of real estate in Florida on Dec. 17, 1993. Joseph moved
to restrain assessment and collection until his petition for
redetermination was heard. In Ripley v. Commissioner, 102 T.C.
(continued...)
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