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because it includes additions to tax and penalties pursuant to a
stipulated decision for 1987 and closing agreements for 1986,
1988, and 1989.
In Pert v. Commissioner, 105 T.C. 370, 377, 380 (1995), we
held that petitioners could not dispute the tax liabilities of
Mr. Riffe and Mrs. Pert because she signed closing agreements for
1986, 1988, and 1989 and agreed to a stipulated decision for
1987. We also held that the statute of limitations does not bar
respondent from assessing transferee liability against
petitioners for 1986. Id. at 379.
We must decide the following issues:
1. Whether Mrs. Pert is liable as a transferee of Mr.
Riffe's assets for his unpaid income tax and additions to tax for
1986, 1987, 1988, and 1989. We hold that she is.1
2. Whether respondent failed to prove the value of the
property transferred from Mr. Riffe's estate to Mrs. Pert, as
petitioners contend; the value of assets transferred is $399,535,
as respondent contends; or the value is some other amount. We
hold that the value of assets transferred is $399,535.
1In light of our holding, we need not decide respondent's
contentions that Mrs. Pert is liable as a fiduciary of Mr.
Riffe's estate for Mr. Riffe's unpaid income tax and additions to
tax for 1986, 1987, 1988, and 1989, and that Mrs. Pert is liable
for Mr. Riffe's unpaid income tax and additions to tax for 1986,
1987, 1988, and 1989, because she signed a statement filed with
the probate court in which she said that she would pay respondent
the taxes which may become due from Mr. Riffe's estate.
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