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 14

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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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