T.C. Memo. 1996-434
UNITED STATES TAX COURT
ESTATE OF IRENE H. GOVERN, DECEASED, REVOCABLE TRUST OF
CHARLES L. GOVERN, SR., TRANSFEREE, JUNE G. HALL,
TRUSTEE AND TRANSFEREE, JUNE G. HALL, TRANSFEREE OF
TRANSFEREE, MURIEL MCNULTY, TRANSFEREE OF TRANSFEREE,
AND VIRGINIA YEGEN, TRANSFEREE OF TRANSFEREE,
Petitioners v. COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket No. 17987-93. Filed September 24, 1996.
Sue Ann Nelson and Tracy M. Smith, for petitioners.
John Schmittdiel, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: Respondent determined that June G. Hall
(petitioner) is liable as trustee and transferee of the revocable
trust of Charles L. Govern, Sr., and as transferee of the estate
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