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LITTLE v. COMMISSIONER

Docket No. 24598-97.

113 T.C. 474 (1999)

WILLIAM D. LITTLE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 29, 1999.

Attorney(s) appearing for the Case

Michael M. Sayers, Michael W. Newport, and Brian K. Rull, for petitioner.

Robert J. Burbank, for respondent.

RUWE, Judge:

Respondent determined that petitioner, in his capacity as a fiduciary of the estate of Jerry J. Calton, is personally liable under 31 U.S.C. section 3713(b) (1994) for the estate's unpaid income tax liabilities in the amount of $63,734.53, plus interest.1 The amounts of the unpaid income tax liabilities of the estate are not in dispute.

Petitioner acknowledges that he permitted all the estate's assets to be...

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