Gumm v. Commissioner
United States Tax Court
Real property of an estate was distributed to petitioners, and the estate, if not already insolvent, was rendered insolvent by the distribution. Held, petitioners are liable under sec. 6901, I.R.C. 1954, as amended, as transferees for the Federal estate tax liability of the estate.
1Opinion of the Court
SWIFT, Judge:
In separate notices of transferee liability, each dated February 15, 1985, respondent determined that petitioners were Hable as transferees for the Federal estate tax deficiency and. addition to tax determined against the estate of Martha O’Hair Kirsten (the estate) as foUows:
Addition to tax
Date of death Estate tax sec. 6651(a)(2)1
May 19, 1980 $9,018.27 $721.46
There is no dispute as to the HabiUty of the estate for the deficiency and addition to tax. The only issue for decision in these consohdated cases is whether petitioners are Hable therefor as transferees of the estate.
At…
2Cases cited31 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Kreps v. CommissionerUnited States Tax Court · 1964
- Leach v. CommissionerUnited States Tax Court · 1953
- Carolyn Brafman v. United StatesCourt of Appeals for the Fifth Circuit · 1967
26 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Hagaman v. CommissionerUnited States Tax Court · 1993
- Peter J. Bresson (Transferee),petitioner-Appellant v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- O'Neal v. CommissionerUnited States Tax Court · 1994
- Merriam v. CommissionerUnited States Tax Court · 1995
- Bresson v. CommissionerUnited States Tax Court · 1998
39 more not listed; retrieve them via the Exa API.