MEMORANDUM OPINION
HAINES, Judge:
Respondent determined a liability of $170,000 plus interest for petitioner as transferee of assets in the Federal estate tax of the Estate of Mary Kabbash (the estate). After concessions, the issue to be decided is whether petitioner is liable for interest on a $170,000 liability as a transferee of the property from the due date of the estate tax return.
Unless otherwise noted, section references are to the applicable...
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