Mary A. Saigh, a.k.a. Mary Saigh, Transferee - Page 1

                                 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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