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of Irene H. Govern for a deficiency in estate tax in the amount
of $285,850 and for an addition to tax under section 6651(a)(1)
in the amount of $71,463. Respondent, by means of separate
notices of transferee liability, further determined that
petitioner, Virginia Yegen, and Muriel McNulty are liable as
transferees of a transferee regarding the estate of Irene H.
Govern each in the amount of $161,969.88.
Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
After concessions,1 the sole issue for decision is whether
petitioner is liable as transferee and trustee under section
6324(a)(2) for unpaid Federal estate tax deficiencies due from
the estate of Irene H. Govern.
Background
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
incorporated by this reference, and the facts contained therein
are found accordingly. Petitioner, trustee of the revocable
trust of Charles L. Govern, Sr., resided in Eagan, Minnesota, at
the time the petition was filed in this case.
1Respondent has conceded that petitioners June G. Hall,
Muriel McNulty, and Virginia Yegen are not liable as transferees
of a transferee (or as successive transferees) for any deficiency
in Federal estate tax or addition to tax owed by the estate of
Irene H. Govern.
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