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FOREHAND v. COMMISSIONER

Docket No. 6850-92.

66 T.C.M. 1763 (1993)

T.C. Memo. 1993-618

James B. Forehand, Jr., Fiduciary Transferee of the Assets of James B. Forehand, Deceased, Transferor v. Commissioner.

United States Tax Court.

Filed December 23, 1993.

Attorney(s) appearing for the Case

Cecil W. Taylor, 1000 Church St., Lynchburg, Va., and Frank W. Rogers, Jr., for the petitioner. Richard Stein, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

By notice of deficiency dated January 9, 1992, respondent determined that petitioner is personally liable, in his capacity as a fiduciary and as the transferee and beneficiary of all the assets of the Estate of James B. Forehand, Sr., for the amount of $100,687.06, being the unpaid estate tax, and $26,711.32, a section 6653(b)1 addition to tax, of the Estate of James...

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