Legal Opinion

RIPLEY v. COMMISSIONER OF INTERNAL REVENUE

United States Tax Court

Decided April 20, 1994No. Docket No. 26402-93Published

D failed to pay the Federal gift tax arising from transfers of property to her son (P) in 1983. R is attempting to collect the Federal gift tax from P based on the special gift tax lien imposed by sec. 6324(b), I.R.C. At the same time, R issued P a notice of transferee liability and P filed a timely petition for redetermination. P filed a Motion to Restrain Assessment and Collection under sec. 6213(a), I.R.C.

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D failed to pay the Federal gift tax arising from transfers of property to her son (P) in 1983. R is attempting to collect the Federal gift tax from P based on the special gift tax lien imposed by sec. 6324(b), I.R.C. At the same time, R issued P a notice of transferee liability and P filed a timely petition for redetermination. P filed a Motion to Restrain Assessment and Collection under sec. 6213(a), I.R.C. Held, P's Motion to Restrain Assessment and Collection will be denied on the ground that R's collection efforts under sec. 6324(b), I.R.C., are not otherwise subject to the normal…

1Opinion of the Court

JOSEPH M. RIPLEY, JR., DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

RIPLEY v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 26402-93

United States Tax Court

102 T.C. 654; 1994 U.S. Tax Ct. LEXIS 28; 102 T.C. No. 26;

April 20, 1994, Filed

An order will be entered denying petitioner's motion to restrain assessment and collection.

D failed to pay the Federal gift tax arising from transfers of property to her son (P) in 1983. R is attempting to collect the Federal gift tax from P based on the special gift tax lien imposed by sec. 6324(b), I.R.C.…

2Cases cited11 opinions

  1. Detroit Bank v. United StatesSupreme Court of the United States · 1943
  2. Estate of Mandels v. CommissionerUnited States Tax Court · 1975
  3. Meyer v. CommissionerUnited States Tax Court · 1991
  4. Powell v. CommissionerUnited States Tax Court · 1991
  5. Kellogg v. CommissionerUnited States Tax Court · 1987

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