- 3 -
David Allen, Transferee
Estate Tax Liability:
Additions to Tax
Sec. Sec. Sec.
Docket No. Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B)
24985-97 $5,835,634 $1,458,909 $291,782 1
1 50 percent of the interest on the portion of the underpayment
attributable to negligence.
Income Tax Liability:
Additions to Tax
Sec. Sec. Sec.
Docket No. Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B)
24984-97 1987 $278,253 $69,563.25 $13,912.65 1
1 50 percent of the interest on the portion of the underpayment
attributable to negligence.
The issues for decision are: (1) Whether David Allen is the
executor of the Estate of Sloan Allen pursuant to section 2203, and
if so, whether the notices of deficiency mailed to him in that
capacity with respect to Federal estate and income taxes and
additions to taxes are valid; (2) whether David Allen is liable as
fiduciary of the Estate of Sloan Allen pursuant to 31 U.S.C.
section 3713(b) (1994), for unpaid Federal estate and income taxes,
and additions to tax, owed by the estate; and (3) whether David
Allen is liable as a transferee pursuant to section 6901 for unpaid
Federal estate and income taxes, and additions to tax, owed by the
estate.
Unless 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