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ESTATE OF SALTER v. COMMISSIONER

Docket No. 8531-72.

63 T.C. 537 (1975)

ESTATE OF MEDORA L. SALTER, NON COMPOS MENTIS, MISSISSIPPI BANK & TRUST COMPANY, CONSERVATOR (JOHN A. SALTER, SUCCESSOR CONSERVATOR), TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 11, 1975.

Attorney(s) appearing for the Case

Joe Jack Hurst and James S. Armstrong, for the petitioner.

Roy S. Fischbeck and Andrew S. Coxe, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined that the Estate of Medora L. Salter, non compos mentis, is liable as transferee for a deficiency of $22,552.99 in the estate tax due from the estate of Cary W. Salter, Sr. (hereinafter sometimes referred to as decedent). Petitioner acknowledges that it is transferee of the assets of the estate of Cary W. Salter, Sr., within the meaning of sections 6324 and 6901,1 but alleges...

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