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EWART v. C.I.R.

No. 86-1050.

814 F.2d 321 (1987)

Roger L. EWART, Fiduciary and Transferee of the Assets of the Estate of Blanche L. Ewart, Deceased, Transferor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided March 23, 1987.

Attorney(s) appearing for the Case

Vincent J. Falcone (argued), Cuyahoga Falls, Ohio, for petitioner-appellant.

Fred T. Goldberg, Jr., Chief Counsel, Washington, D.C., Michael L. Paup, Roger M. Olsen, David English Carmack, Jane S. Kimball (argued), for respondent-appellee.

Before JONES and GUY, Circuit Judges; EDWARDS, Senior Circuit Judge.

NATHANIEL R. JONES, Circuit Judge.

Roger L. Ewart (the taxpayer) appeals from a decision of the United States Tax Court holding him liable as a transferee of the assets of the Estate of Blanche L. Ewart (the estate) under section 6901(a)(1)(A)(ii) of the Internal Revenue Code of 1954, 26 U.S.C. [I.R.C.] § 6901(a)(1)(A)(ii) (1982). See Ewart v. Commissioner, 85 T.C. 544 (1985). For the reasons set forth below, we affirm....

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