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in the farm acreage, the residence acreage, and the 20-acre carve
out, and the portion of such fair market value which Richard
transferred to each of petitioners, namely, Carrie, Tracy, and
Deborah, for no consideration.
Transfer of Richard’s One-Half Interests
Fair Market Value Received By
Property Value Carrie Tracy Deborah
Farm Acreage $72,108* $24,036 $24,036 $24,036
Residence
Acreage 16,984 16,984 --- ---
20-Acre Carve Out 10,000 10,000 --- ---
Total Transferee
Liability $51,020 $24,036 $24,036
(*$88,000 less $15,892 equals $72,108)
The above amounts establish the transferee liabilities of
Carrie, Tracy, and Deborah relating to Richard’s Federal income
tax liabilities for 1995 and 1996, including penalties. The
transferee liabilities of Carrie, Tracy, and Deborah accrue
interest from the date of respondent’s notices of transferee
liability to each petitioner.7
Decisions will be entered
under Rule 155.
7 Under Maine law, respondent seeks interest relating to
petitioners’ transferee liabilities only from Aug. 6, 2002, the
date of his notices of transferee liability to petitioners. Me.
Rev. Stat. Ann. tit. 14, sec. 1602; sec. 6601(e); Estate of Stein
v. Commissioner, 37 T.C. 945, 959-961 (1962).
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