Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 19

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          pursuant to an arrangement with the donor, would be in a "net               
          gift" transaction.  Petitioners are liable as transferees for the           
          amount of property they received by gift because the donor did              
          not satisfy her primary obligation for the gift tax owed.                   
               Had a "net gift" been made, petitioners would have paid the            
          resulting gift tax and the amount of the gift would have been               
          reduced accordingly.  However, if the donor had not paid the full           
          amount of gift tax owed for that period, petitioners still would            
          remain liable as transferees up to the full amount of the gift              
          pursuant to section 6324(b).  See LaFortane v. Commissioner, 29             
          T.C. 479, 489 (1957), affd. 263 F.2d 186, 194 (10th Cir. 1958).             
          The end result is that petitioners could be required to pay the             
          full value of the property received.  A portion would be paid as            
          tax (the gift tax paid for the donor as consideration for the               
          "net gift"), and a portion would be paid to satisfy their                   
          transferee liability, up to the full value of the gift received.            
               What petitioners argue for here is a result better than what           
          they could receive had a net gift been made.  In essence, what              
          petitioners argue is that any amount they now are required to pay           
          should "purchase" a portion of the property they received,                  
          ultimately leaving them liable for less than the full value of              
          what was transferred to them.  Rev. Rul. 75-72, supra, provides             
          no support for such an argument.  Petitioners' liability herein             
          is their personal liability to the Government, measured by what             






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