T.C. Memo. 2005-20
UNITED STATES TAX COURT
MARY A. SAIGH, a.k.a. MARY SAIGH, TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11599-03. Filed February 8, 2005.
John R. Holsinger, for petitioner.
William C. Bogardus, for respondent.
MEMORANDUM OPINION
HAINES, Judge: Respondent determined a liability of
$170,000 plus interest for petitioner as transferee of assets in
the Federal estate tax of the Estate of Mary Kabbash (the
estate). After concessions, the issue to be decided is whether
petitioner is liable for interest on a $170,000 liability as a
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