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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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Last modified: May 25, 2011