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that date timely mailed to Carrie, Tracy, and Deborah notices of
transferee liability in the respective amounts indicated below
relating to Richard’s outstanding Federal income tax liabilities,
penalties, and interest, for 1995 and 1996:5
Petitioner Amount
Carrie H. Suchar $51,394
Tracy L. Suchar 25,000
Deborah R. Suchar 25,000
In September 2002, at the request of Carrie, Tracy, and
Deborah, a Maine certified general appraiser by the name of
Laurent L’Heureux valued the farm acreage, as of September 9,
1998, at a fair market value of $87,000.
In December of 2002, Tracy and Deborah filed deeds
transferring their interests in the farm acreage to Carrie.
OPINION
Under section 6901 and applicable State law or equity,
respondent may be allowed to collect from a transferee of assets
5 Because Richard’s 1994 and 1995 Federal income tax
returns were filed on Aug. 17 and Sept. 28, 1998, respectively,
the periods of limitations with respect thereto for assessment of
tax deficiencies would have expired on Aug. 17, 2001, and
Sept. 28, 2001, respectively. Accordingly, under sec. 6901(c),
the periods of limitations for assessment of transferee
liability relating to those years would have expired on Aug. 17
and Sept. 28, 2002, respectively, one year after the period of
limitations on assessment expired. Therefore, respondent’s
notices of transferee liability to Carrie, Tracy, and Deborah
were issued timely on Aug. 6, 2002.
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