Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 14

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          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.                        




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