Frank Armstrong, III, Transferee, et al. - Page 1

                                   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.           

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011