- 21 -
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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