- 12 - (c) Period of limitations.--The period of limitations for assessment of any such liability of a transferee or a fiduciary shall be as follows: (1) Initial transferee.--In the case of the liability of an initial transferee, within 1 year after the expiration of the period of limitation for assessment against the transferor. The FPAA was sent to the decedent and the tax matters partner of EXOCO on March 26, 1986. The tax matters partner filed a petition with this Court on June 20, 1986. The decision of this Court was entered pursuant to a settlement among the parties to the action on April 30, 1992, and became final 90 days later. An assessment in the amount of $18,247 was made against the decedent on February 15, 1993. The statutory notice of transferee liability for the assessed amount plus interest was mailed to petitioner on July 22, 1994. The assessment is not time barred, nor is petitioner's liability as transferee. Petitioner has advanced other arguments with regard to the partnership item. She contends, for example, that she was precluded by the absence of notice from negotiating a settlement offered to other partners. The assessment, however, was made based on the decision entered pursuant to the settlement reached in the partnership proceeding. Other arguments related to the decedent's investment in EXOCO cannot be addressed in this proceeding for reasons set forth above. Transferee LiabilityPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011