Frank Armstrong, III, Transferee, et al. - Page 5




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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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