- 2 -
Held: Ps are transferees of property the value of
which is treated as if included in D's gross estate
pursuant to sec. 2035(d)(3)(C), I.R.C., and are, to the
extent of the value of such property at the time of D's
death, personally liable for unpaid estate taxes
pursuant to sec. 6324(a)(2), I.R.C. Held, further,
Ps' motions for partial summary judgment will be
denied.
Charles S. McCandlish and Aubrey J. Owen, for petitioners.
Cheryl M.D. Rees, for respondent.
OPINION
DAWSON, Judge: These cases were assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(5) and Rules 180, 181, and 183.2 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: These cases are before
the Court on petitioners' Motions for Partial Summary Judgment.
Petitioners contend that they are entitled to summary judgment
that they are not liable as transferees. As discussed in detail
below, we will deny petitioners' motions.
2 Section references are to the Internal Revenue Code, as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
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