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HARRY C. PORTER, TRANSFEREE v. COMMISSIONER

Docket Nos. 2084-66, 2085-66.

49 T.C. 207 (1967)

HARRY C. PORTER, TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF ROBERT P. PORTER, JR., DECEASED, TRANSFEREE, S. HOLT McALONEY AND FERN W. PORTER, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 13, 1967.

Attorney(s) appearing for the Case

William C. Schaab, for the petitioners.

Frederick B. Strothman, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in the estate tax liability of the Estate of Alice M. Porter in the amount of $92,536.16 and an addition to tax for failure to file an estate tax return in the amount of $23,134.04.1 Respondent asserted that petitioners are liable as transferees of the assets of the Estate of Alice M. Porter.

The issues for decision are: (1) Whether...

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