Mary A. Saigh, a.k.a. Mary Saigh, Transferee - Page 10

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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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