Docket No. 19310-94.

72 T.C.M. 1481 (1996)

T.C. Memo. 1996-541

Anna Lee Locke v. Commissioner.

United States Tax Court.

Filed December 16, 1996.

Attorney(s) appearing for the Case

Anna Lee Locke, pro se. Jack Klinghoffer, for the respondent.


COHEN, Chief Judge:

Respondent determined that petitioner was liable as a transferee of Alexander Locke, Jr., for an income tax liability of $18,247 for 1982. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The issues for decision are: (1) Whether the statute of...

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