Jimmy D. Morris, Transferee - Page 21




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                 Accordingly, we hold that respondent is not time barred from                          
            assessing transferee liability against petitioner.                                         
            Conclusion                                                                                 
                 Petitioner is liable as a transferee for ACT’s income tax                             
            deficiencies and additions to tax up to, but not exceeding,                                
            $199,490, plus interest, for the tax liabilities due and                                   
            uncollected from ACT for the 1988 taxable year.14                                          
                 To reflect the foregoing,                                                             
                                                           Decision will be entered                    
                                                     under Rule 155.                                   
















                  14 The parties have not addressed the manner in which                                
            interest is to be computed.  We expect this matter to be resolved                          
            in the Rule 155 computation.  For an analysis of the computation                           
            of interest under Florida law where the amount transferred to a                            
            transferee is less than the amount of taxes owed by the                                    
            transferor, see Griffin v. Commissioner, T.C. Memo. 1997-394.                              









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