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ESTATE OF GOVERN v. COMMISSIONER

Docket No. 17987-93.

72 T.C.M. 725 (1996)

T.C. Memo. 1996-434

Estate of Irene H. Govern, Deceased, Revocable Trust of Charles L. Govern, Sr., Transferee, June G. Hall, Trustee and Transferee, June G. Hall, Transferee of Transferee, Muriel McNulty, Transferee of Transferee, and Virginia Yegen, Transferee of Transferee v. Commissioner.

United States Tax Court.

Filed September 24, 1996.

Attorney(s) appearing for the Case

Sue Ann Nelson and Tracy M. Smith, Minneapolis, Minn., for the petitioners. John Schmittdiel, for the respondent.

MEMORANDUM OPINION

HAMBLEN, Judge:

Respondent determined that June G. Hall (petitioner) is liable as trustee and transferee of the revocable trust of Charles L. Govern, Sr., and as transferee of the estate of Irene H. Govern for a deficiency in estate tax in the amount of $285,850 and for an addition to tax under section 6651(a)(1) in the amount of $71,463. Respondent, by means of separate notices of transferee liability, further determined that petitioner...

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