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were liable as transferees relating to their father Richard
Suchar’s (Richard) Federal income tax liabilities for the years
1995 ($23,278) and 1996 ($20,238), plus penalties and interest.
Based on respondent’s determination as to the value of
assets transferred by Richard to Carrie, Tracy, and Deborah,
respondent determined that the amounts of the respective
transferee liabilities of Carrie, Tracy, and Deborah relating to
Richard’s above Federal income tax liabilities, penalties, and
interest, were as follows:2
Carrie Tracy Deborah
$51,394 $25,000 $25,000
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time they filed their petitions, Carrie resided in Maine,
and Tracy and Deborah resided in California.
2 To the extent the Court’s conclusions herein as to the
value of Richard’s property that was transferred to petitioners
are higher than the value therefor initially determined by
respondent, respondent has pending a motion to increase
petitioners’ transferee liabilities accordingly.
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Last modified: May 25, 2011