T.C. Memo. 1996-249
UNITED STATES TAX COURT
JOHN CHRISTOPHER SINGLETON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4164-94. Filed May 30, 1996.
John C. Singleton, pro se.
T. Keith Fogg and Veena Luthra, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined that petitioner in his
capacity as a fiduciary of the Estate of Marguerite B. Greer
(sometimes referred to as the Estate) was personally liable under
31 U.S.C. section 3713(b) (1994) for unpaid estate taxes owing by
the Estate in the amount of $32,443, plus interest. Respondent
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