- 2 - 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.Page: 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