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.
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