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the applicable limitation period. Accordingly, such notices were
timely.
In light of the foregoing, we hold that the decision
entered by the Court in Estate of Mickler v. Commissioner,
docket No. 15954-94, is not dispositive as to petitioners'
transferee liability for the estate tax deficiency. For the
reasons stated herein, petitioners' motion for partial summary
judgment is denied.3
An appropriate order
denying petitioners' Motion
for Partial Summary Judgment
will be issued.
3The facts of the instant case are virtually identical to
those in Estate of King v. Commissioner, T.C. Memo. 1991-151.
The two cases, however, are technically distinguishable in one
major respect. In Estate of King v. Commissioner, supra,
respondent conceded that the technical elements of res judicata
had been satisfied. This concession contributed to a decision in
the taxpayer's favor. In contrast, respondent makes no such
concession in the instant case.
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