David Allen - Page 18




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               2.   David was the fiduciary (personal representative) of              
          Sloan's estate within the purview of 31 U.S. section 3713(b).               
          David is responsible for the payment of income and estate taxes, as         
          well as additions to tax, owed by Sloan's estate.                           
               3.   After Sloan's death on March 8, 1987, his estate was              
          insolvent. As personal representative of Sloan's estate, David              
          transferred to himself all the assets of Sloan’s estate.  David is          
          liable as a transferee of the assets of Sloan’s estate for the              
          income and estate taxes, as well as additions to tax, owed by               
          Sloan's estate.                                                             
                                       OPINION                                        
               Preliminarily, we must determine whether Sloan's purported             
          signatures on the stock certificates (representing the 110,000              
          shares) and checks (hereinafter referred to as stock certificates           
          and checks) were genuine.                                                   
          Handwriting Experts                                                         
               Each party presented an expert to determine the genuineness of         
          Sloan's purported signatures on the stock certificates and checks.          
          The experts agreed that Sloan's purported signatures on the stock           
          certificates and checks were either traced or simulated;1 thus,             




               1    A “tracing” occurs where an individual creates a                  
          mechanical copy of another's signature by handwriting.                      
          “Simulated” is defined as an effort to copy the handwriting style           
          or characteristics of another.                                              




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