Estate of Florence H. Devida Johnson - Page 12




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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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