- 14 - period on April 7, 1992, we find that the Form 872 executed in this case is an extension agreement as described in section 6501(c)(4). As such, the agreement is independently subject to the application of section 6503(a)(1), which suspends the running of the limitations period "until the decision of the Tax Court becomes final and for 60 days thereafter." As described in detail above, the limitations period of the donor would expire no earlier than October 1, 1992. According to section 6901(c)(1), the 1-year extension for assessment against a transferee would expire no earlier than October 1, 1993. Because the notice of donee/transferee liability to each petitioner was issued on September 17, 1993, each notice was timely. 2. The Amount of Petitioners' Transferee Liability Having concluded that the Commissioner's assessment is not barred by the statute of limitations, we turn to the amount owed by petitioners. The donor entered into a stipulated decision which found a deficiency in gift tax for 1983 in the amount of $239,124. Section 6324(b), however, limits the liability of a donee to the value of the gift received. The Commissioner accordingly issued to each petitioner a notice of donee/transferee liability in the amount of $93,300.4 Petitioners argue that their liability should be reduced by the amount of gift tax they now will be required to pay. 4 There is no dispute between the parties that the value of the property transferred to petitioners was $93,300.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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