- 5 - distributions from the estate were made on the advice of Mr. Lahr. Petitioner and Mr. Lahr had no actual knowledge of the estate’s income tax liabilities at the time these disbursements and distributions were made.2 In January 1990, petitioner, in his capacity as personal representative of the estate, received Forms W-2 and Forms 1099 for decedent which indicated that decedent had income in 1989. In January 1991, petitioner also received Forms 1099 indicating 2Both petitioner and Mr. Lahr were credible when they testified to their ignorance of the tax liabilities in question. Indeed, respondent had no objection to petitioner’s requested findings of fact, which stated: Mr. Lahr was unaware of and ignorant of the debts due the Government at the time distributions were made to beneficiaries. Petitioner was unaware of and ignorant of the debts due the Government at the time distributions were made to beneficiaries.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011