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SWARTZ v. COMMISSIONER

Docket No. 15624-79.

42 T.C.M. 1283 (1981)

T.C. Memo. 1981-566

Stanley Joseph Swartz, II, Transferee v. Commissioner.

United States Tax Court.

Filed September 30, 1981.

Attorney(s) appearing for the Case

Robert G. Ray, 12 South Cherry St., Lebanon, Ohio, for the petitioner. Robert J. Kastl, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a liability against petitioner as transferee of the assets of the estate of Carol Ann Swartz, deceased, in the amount of $2,902.26, consisting solely of an addition to tax under the provisions of section 6651 (a)(1), Internal Revenue Code of 1954,1 for the late filing of the estate tax return. The sole issue for our decision is whether the failure...

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