This is a proceeding for the redetermination of the liability asserted against petitioner as trustee and transferee in the amount of $94,803.62 for the unpaid balance of the estate tax due on the estate of Laura Etnier Austin. The only issue in the proceeding relates to the extent of petitioner's liability as trustee and transferee under sections 827 (b) and 900 of the Internal Revenue Code.
FINDINGS OF FACT.
The facts herein were stipulated and they are...
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