Roger L. Ewart, Fiduciary and Transferee of the Assets of the Estate of Blanche L. Ewart, Deceased, Transferor v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
NATHANIEL R. JONES, Circuit Judge.
Roger L. Ewart (the taxpayer) appeals from a decision of the United States Tax Court holding him liable as a transferee of. the assets of the Estate of Blanche L. Ewart (the estate) under section 6901(a)(1)(A)(ii) of the Internal Revenue Code of 1954, 26 U.S.C. [I.R.C.] § 6901(a)(1)(A)(ii) (1982). See Ewart v. Commissioner, 85 T.C. 544 (1985). For the reasons set forth below, we affirm.
The following facts are taken largely from the Tax Court’s opinion. Blanche L. Ewart died on April 30, 1978, and her will was probated in the Ohio courts. Taxpayer, and his…
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