Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 4

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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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