Estate of Irene H. Govern, Deceased, Revocable Trust of Charles S. Govern, Sr., Transferee, June G. Hall, Trustee and Transferee, June G. Hall, Transferee of Transferee, Muriel McNulty, Transferee o - Page 8

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          Federal estate tax or addition to tax had been paid by or for the           
          account of decedent's estate.  Both decedent's estate and the               
          Marital Trust are insolvent as all assets of decedent's estate,             
          including the Marital Trust assets, have been distributed to                
          Charles L. Govern II.                                                       
                                     Discussion                                       
          I. Liability Under Section 6324(a)(2)                                       
               Section 6901(a)3 establishes a procedure for the assessment            
          and collection by the Commissioner of unpaid Federal income,                
          estate, or gift tax liability from a transferee.  Section 6901              
          does not create or define a transferee's substantive tax                    
          liability, and the substantive basis for the assertion of                   
          transferee liability under section 6901 must generally be found             

               2(...continued)                                                        
          we entered a stipulated decision on Aug. 1, 1995, that resolved             
          the amount of the underlying deficiency in estate tax and                   
          addition to tax due from decedent's estate.                                 
               3Sec. 6901(a) provides, in pertinent part:                             
                    SEC. 6901(a). Method of Collection.--The amounts                  
               of the following liabilities shall, except as                          
               hereinafter in this section provided, be assessed,                     
               paid, and collected in the same manner and subject to                  
               the same provisions and limitations as in the case of                  
               the taxes with respect to which the liabilities were                   
               incurred:                                                              
                    (1) Income, estate, and gift taxes.--                             
                              *   *   *   *   *   *   *                               
                         (ii) of a decedent in the case of a tax                      
                    imposed by chapter 11 (relating to estate taxes),                 
                    or                                                                




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