- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011