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v. Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may
be granted with respect to all or any part of the legal issues in
controversy "if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
together with the affidavits, if any, show that there is no
genuine issue as to any material fact and that a decision may be
rendered as a matter of law." Rule 121(b); Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th
Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988);
Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Section 6901 sets forth the procedures that are applicable
prior to the assessment and collection of an income, estate, or
gift tax liability from a transferee. Section 6901(a)(1)(A)(ii)
provides:
SEC. 6901. TRANSFERRED ASSETS.
(a) Method of Collection.--The amounts of the
following liabilities shall, except as hereinafter in
this section provided, be assessed, paid, and collected
in the same manner and subject to the same provisions
and limitations as in the case of the taxes with
respect to which the liabilities were incurred:
(1) Income, estate, and gift taxes.--
(A) Transferees.--The
liability, at law or in equity, of
a transferee of property--
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