- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011