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value of the shares as estimated by the IRS. The parties have
since stipulated that the value of the shares on the date of the
transfer was $53,828.12.
OPINION
We must decide whether petitioner may be held liable as a
transferee for unpaid taxes of Mr. Espinosa, from whom she
received assets worth $53,828.12.
I. General Rules
A. Transferee Liability
Section 6901, which establishes a procedure whereby
respondent may assess and collect from a transferee of property
the unpaid taxes of the transferor, reads in part as follows:
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--
(i) of a taxpayer in the case of a
tax imposed by subtitle A (relating to
income taxes),
* * * * * * *
The foregoing section thus does not create or define a
substantive liability; rather, it merely provides a remedy for
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