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We find that respondent has proved that petitioner was the
trustee and person in possession of the Marital Trust property on
the date of decedent's death. Furthermore, there is a deficiency
in decedent's estate's Federal estate tax for $12,321 and an
addition to tax, under the provisions of section 6651(a), for
$3,080 due from decedent's estate. Accordingly, pursuant to
section 6324(a)(2), petitioner is personally liable, to the
extent of the value of the Marital Trust property at the date of
decedent's death, for the Federal estate tax, addition to tax,
and interest due from decedent's estate. Because the value of
the Marital Trust property ($412,500) is far more than the unpaid
estate tax deficiency ($12,321) and addition to tax ($3,080),
petitioner is liable as transferee for the entire unpaid amount.
Petitioner contends that even if section 6324(a)(2) imposes
personal liability upon her, she should be held liable only for
the deficiency in decedent's estate's Federal estate tax of
$12,321 and not for the addition to tax under the provisions of
section 6651(a) for $3,080. We disagree. Once the Commissioner
has established transferee liability, the transferee is liable
for the transferor's taxes due as of the time of the transfer, as
well as interest and any additions to tax, to the extent of the
value of the assets transferred. Estate of Glass v.
Commissioner, 55 T.C. 543, 575-576 (1970), affd. 453 F.2d 1375
(5th Cir. 1972).
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