Carrie H. Suchar, Transferee, et al. - Page 17

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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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