- 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
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