Crawford v. Commissioner

Pursuant to a jeopardy assessment of deficiencies in the individual income taxes of the residuary legatee-executor of decedent's estate, respondent served notices of levy upon certain third parties during the time the estate was in administration for property belonging to the residuary legatee-executor as beneficiary of the estate. Prior to the issuance of the notice of deficiency herein, respondent received from the parties upon whom such levies had been served, cash and other assets belonging to the estate in amounts more than sufficient to satisfy the entire tax liability of the estate…