114 T.C. No. 5 UNITED STATES TAX COURT FRANK ARMSTRONG, III, TRANSFEREE, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7267-98, 7269-98, Filed February 28, 2000. 7270-98, 7274-98. D transferred a substantial portion of his assets to Ps within 3 years of his death. After paying the Federal gift taxes associated with these gifts, D was nearly insolvent. Following D's death, R determined a deficiency in Federal estate tax due from D's estate attributable to the estate's failure to include in the gross estate the gift taxes that D paid on the aforementioned gifts. See sec. 2035(c), I.R.C. R subsequently issued notices of transferee liability to Ps who filed timely petitions for redetermination with the Court. Ps filed motions for partial summary judgment alleging that they are not liable as transferees as a matter of law. 1 Cases of the following petitioners are consolidated herewith: William Armstrong, Transferee, docket No. 7269-98; Gretchen A. Redmond, Transferee, docket No. 7270-98; JoAnne Armstrong-Jones, f.k.a. JoAnne A. Strader, Transferee, docket No. 7274-98.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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