- 5 -
817-818 (1977), affd. 41 AFTR 2d 78-328, 78-1 USTC par. 9153 (2d
Cir. 1977). We sustain respondent’s determination that decedent
was taxable on unreported interest income of $7,435 from
custodial accounts in 2000.
Ms. Bryan nevertheless contends that a deceased person
should not be liable for any tax deficiencies. “Death may be an
avenue of escape from many of the woes of life, but it is no
escape from taxes.” Estate of Kahr v. Commissioner, 414 F.2d
621, 626 (2d Cir. 1969) (cited by United States v. Critzer, 498
F.2d 1160, 1163 (4th Cir. 1974)), affg. in part and revg. in part
48 T.C. 929 (1967).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent with respect to
the deficiency and for
petitioner with respect to the
addition to tax under section
6651(a)(1).
4(...continued)
Trusts sec. 13-314(b) (2001). In the alternative, a custodian
may deliver or pay to the minor, without a court order, so much
of the custodial property as the custodian considers advisable
for the use and benefit of the minor. See id. sec. 13-314(a).
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