Tuesday, April 26, 2005
In Saigh It Isn't So, 107 Tax Notes 115 (Apr. 4, 2005), Prof. Wendy Gerzog examines the Saigh case.
In Saigh, while conceding transferee liability up to the value of the property transferred to her from the decedent’s estate, the estate beneficiary argued that she was not liable for interest.
The article reviews the opposing holdings in the Eleventh and Eighth Circuit’s holdings in the brothers’ Baptiste cases on the same section 6324 issue. In addition, the article examines the fiduciary liability cases wherein the Tax Court reached opposite conclusions from its holding in Baptiste.