Phyllis Berliant, Transferee v. Commissioner of Internal Revenue, Florence Kraft, Transferee v. Commissioner of Internal Revenue

CUMMINGS, Chief Judge.

This is an appeal by Florence Berliant Kraft (Kraft) and Phyllis Berliant (Berliant) from a decision of the United States Tax Court finding Kraft, Berliant and Irene Berliant Magill 1 liable for unpaid taxes of the estate of decedent Rae Berliant (Rae). Magill v. Commissioner, 51 TCM (P-H) ¶ 82,148 (filed March 24, 1982) (App. 1-53). Tax Court Judge Dawson determined that the estate tax owed was $67,-294.85 plus interest and that the parties were each liable for the tax to the extent of the value of assets received (App. 54). Kraft and Magill, transferees of both probate…