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estate, at the expense of the government, for as long as
possible with no adverse consequences.
Id. at 1542-1543 n.9.
The facts in the instant case mirror the facts in Baptiste
v. Commissioner, supra; i.e., the transferee received amounts
from a decedent less than the estate tax liability, the estate
tax was unpaid, and respondent sought to impose the estate tax
liability on the transferees. On the basis of our holding and
the holding of the Court of Appeals in Baptiste v. Commissioner,
supra, we hold that petitioner is liable for interest on the
$170,000 determined in the notice of transferee liability as a
transferee of the property of the estate from the due date of the
estate tax return pursuant to sections 6601(a), 6324(a)(2), and
6901(a).
In reaching our holding herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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