John Christopher Singleton, (1996)

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John Christopher Singleton, (1996)

T.C. Memo. 1996-249

UNITED STATES TAX COURT JOHN CHRISTOPHER SINGLETON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4164-94. Filed May 30, 1996.

John C. Singleton, pro se. T. Keith Fogg and Veena Luthra, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION JACOBS, Judge: Respondent determined that petitioner in his capacity as a fiduciary of the Estate of Marguerite B. Greer (sometimes referred to as the Estate) was personally liable under 31 U.S.C. section 3713(b) (1994) for unpaid estate taxes owing by the Estate in the amount of $32,443, plus interest. Respondent -2-reflected this determination in a notice of liability mailed to petitioner on December 21, 1993.

Petitioner acknowledges that he permitted Estate assets to be distributed before all estate taxes had been paid; however, he disputes personal liability for the unpai...

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