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PHILLIPP v. COMMISSIONER

Docket Nos. 5028-76, 5029-76.

36 T.C.M. 549 (1977)

T.C. Memo. 1977-126

Charles J. Phillipp, Transferee v. Commissioner. Josephine D. Phillipp, Transferee, and Josephine D. Phillipp, Executrix of the Estate of Ambrose F. Phillipp v. Commissioner.

United States Tax Court.

Filed May 2, 1977.

Attorney(s) appearing for the Case

Ronald H. McConnell, for the petitioners. Robert N. Armen, Jr., for the respondent.

Memorandum Opinion

TIETJENS, Judge:

Respondent determined an assessment against Charles J. Phillipp in the amount of $4,921.14 as his liability as a transferee of property of the Estate of Ambrose F. Phillipp for "deficiency interest due on estate tax."

He also determined an assessment against Josephine D. Phillipp in the same amount which constituted her "personal liability as a fiduciary for deficiency interest due on estate tax from the Estate...

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