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SCOTT v. COMMISSIONER

Docket No. 2165-85.

52 T.C.M. 1087 (1986)

T.C. Memo. 1986-566

Elsie E. Scott, Transferee of Assets of Thomas J. Scott v. Commissioner.

United States Tax Court.

Filed November 25, 1986.

Attorney(s) appearing for the Case

Lee N. Johnson, 800 Title Insurance Building, 400 Second Ave. S.W., Minneapolis, Minn., for the petitioner. Andrew P. Fradkin, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined that petitioner was liable as transferee of Thomas J. Scott for an income tax deficiency of $25,675.40 and an addition to tax pursuant to section 66541 of $1,967.39. After concessions, the issues for decision are: (1) Whether Thomas J. Scott received unreported taxable income in 1981 and (2) to what extent, if any, petitioner Elsie E. Scott is liable...

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