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that amount exceeds the value of the assets transferred.
Respondent urges us to extend the holding in Baptiste to this
case of fiduciary liability and hold that Ms. Johnson's fiduciary
liability extends to interest accrued on the obligation until
paid. We have previously declined to do so, see Singleton v.
Commissioner, T.C. Memo. 1996-249, and we decline to do so again
in this case. We sustain respondent's determination of fiduciary
liability relating to Mr. Johnson's 1979, 1980, 1981, and 1983
taxes and additions to tax, and hold that Ms. Johnson is
personally liable for Mr. Johnson's outstanding tax obligations
for those years, plus interest on those obligations as provided
by law, not to exceed $30,000.
In reaching all our holdings herein, we have considered each
argument made by the parties, and, to the extent not discussed
above, find those arguments to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011