- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011