- 117 -
we hold that Larry, Ronnie, and Sylvia are liable as transferees
under section 6901(a). Their liability is limited, however, to
the value of the cash and other assets Frank and Katherine
transferred to them. Except for those items addressed supra, the
parties have agreed to the amounts of those transfers.
Accordingly, in determining transferee liability the cash and
other assets must be adjusted to accord with the agreement of the
parties and our holdings in the instant cases.37 See Hagaman v.
Commissioner, supra at 180 n.1; Gumm v. Commissioner, supra at
480.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
37 We note that for purposes of the notices of transferee
liability in determining the value of assets transferred upon
which transferee liability attached for Larry and Ronnie
respondent used the total fair market value for the Longwood
property for each of them without regard to the fact that they
each had only a one-half interest in that property. An
appropriate adjustment is needed to account for the one-half
interest.
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