Memorandum Opinion
LARO, Judge.
David Shawn Beckwith petitioned the Court to redetermine respondent's determination that he is personally liable for $36,574.57 in Federal estate tax owed by the Estate of Gladys C. Beckwith (the Estate), as a fiduciary of the Estate and as a transferee of its assets.
Respondent moves the Court for summary judgment under Rule 121.
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