Anna Lee Locke - Page 17

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          establish a different value for the items on the estate tax                 
          return.                                                                     
               Because the decedent's entire estate was transferred to                
          petitioner upon the decedent's death, the estate became insolvent           
          as a result of the transfer.                                                
               Respondent has satisfied her burden and established                    
          transferee liability.  Accordingly, petitioner is liable for the            
          amount of the deficiency plus any allowable interest to the                 
          extent that it does not exceed the amount the decedent                      
          transferred to petitioner.  Yagoda v. Commissioner, 39 at 185.              
          Notwithstanding the items that petitioner attempted to revalue,             
          petitioner's undisputed receipt of the amounts listed as                    
          annuities in the decedent's estate tax return would have provided           
          petitioner with funds exceeding petitioner's transferee                     
          liability.  Because the value of the items transferred exceeds              
          the transferee liability, petitioner is liable for the entire               
          amount determined.  Yagoda v. Commissioner, Id. at 185; Brown v.            
          Commissioner, 24 T.C. 256, 267 (1955).                                      
               Finally, petitioner asserts that, if she is liable as a                
          transferee, she should be relieved of her liability because she             
          is an "innocent spouse".  Petitioner argues that it is                      
          inequitable to hold her responsible for the amounts due,                    
          particularly for the interest.                                              
               Respondent asserts that the "innocent spouse" defense is not           
          available in a transferee liability case.  Respondent further               




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