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PERT v. COMMISSIONER

Docket Nos. 13783-94, 13784-94.

73 T.C.M. 2426 (1997)

T.C. Memo. 1997-150

Harvey M. Pert, Transferee v. Commissioner. Kathleen M. Pert, f.k.a. Kathleen M. Riffe, Transferee v. Commissioner.

United States Tax Court.

Filed March 24, 1997.

Attorney(s) appearing for the Case

B. Gray Gibbs, St. Petersburg, Fla., for the petitioners. Michael A. Pesavento, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Kathleen M. Pert (Mrs. Pert), formerly known as Kathleen M. Riffe, was married to Timothy C. Riffe (Mr. Riffe) until he died, and later married to Harvey M. Pert (Mr. Pert). Mr. Riffe and Mrs. Pert filed joint income tax returns from 1986 to 1989.

Respondent determined that Mrs. Pert is liable as a transferee of the assets of Mr. Riffe for his and Mrs. Pert's unpaid income tax and interest and...

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