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RIPLEY v. COMMISSIONER

Docket No. 26209-93.

105 T.C. 358 (1995)

WALTER R. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR, AND MELYNDA H. RIPLEY, DONEE-TRANSFEREE OF MILDRED M. RIPLEY, DONOR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 8, 1995.

Attorney(s) appearing for the Case

G. Nelson Mackey, Jr., for petitioners.

Scott Anderson, for respondent.

OPINION

RAUM, Judge:

Respondent issued notices of donee/transferee liability to petitioners, each in the amount of $93,300. At issue is: (1) Whether the period of limitations for assessment of transferee liability prescribed by section 6901(c)(1)1 had expired, and (2) the amount of petitioners' transferee liability under section 6324(b).

The liability at issue results from gifts made by Mildred M. Ripley (donor...

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