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 18

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          III.  Conclusion                                                            
               Under section 6324(a)(2) Congress imposed liability for                
          unpaid Federal estate taxes on a trustee, such as petitioner, who           
          has at the date of a decedent's death, assets included in the               
          decedent's gross estate under sections 2034 to 2042, inclusive,--           
          in this case, under section 2041.  We conclude that respondent              
          has established that petitioner is personally liable as a trustee           
          of property of decedent's estate pursuant to section 6324(a)(2)             
          for decedent's estate's unpaid Federal estate tax and addition to           
          tax.  We have considered all other arguments made by petitioner             
          and find them to be without merit.                                          
               To reflect the foregoing and concessions by the parties,               

                                             Decision will be entered under           
                                        Rule 155.                                     






















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