Harvey M. Pert, Transferee v. Commissioner

105 T.C. No. 24

UNITED STATES TAX COURT HARVEY M. PERT, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent KATHLEEN M. PERT, F.K.A. KATHLEEN M. RIFFE, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 13783-94, 13784-94. Filed November 15, 1995. Kathleen M. Pert signed closing agreements (Forms 866) pursuant to sec. 7121 I.R.C., for tax years 1986, 1988, and 1989 for both herself and as personal representative of the estate of her deceased husband, Timothy C. Riffe. Respondent accepted the closing agreements. Timothy Riffe and Kathleen Pert…