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facts before us support a conclusion that petitioner fulfilled
his duty of inquiry and was reasonable and acted in good faith in
following the attorney’s advice that no tax was due from the
estate. In the unique circumstances of this case, we find that
petitioner lacked knowledge of the estate’s income tax
liabilities at the time he made payments from the estate’s assets
and did not knowingly disregard debts due to the United States.
We therefore hold that petitioner is not liable under 31 U.S.C.
section 3713(b) for the unpaid tax liabilities in question.
Decision will be entered
for petitioner.
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