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1992, in the amount of $87,516, plus interest as provided by
law.1 Respondent determined, and petitioners concede, for the
purposes of this proceeding, that Mr. Fisher's unpaid 1991 and
1992 deficiencies and additions to tax are:
Addition to Tax
Year Deficiency Sec. 6663
1991 $52,165 $40,865
1992 30,771 23,078
The issue for decision is whether petitioners are liable as
the transferees of assets of Mr. Fisher under section 6901,2 and,
if so, the amount of such liability.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Tallahassee, Florida, at the time they
filed their petition. Petitioners were married to each other
throughout the period relevant to this case. Mrs. Griffin and
Mr. Fisher are sister and brother.
1The notice of transferee liability, issued to petitioners
on July 7, 1994, determined a liability of $84,467. In an
amended answer, respondent increased the amount of transferee
liability asserted against petitioners to $87,516.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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