Saigh it Isn't so!

Abstract

Recently, in Saigh v. Commissioner, the petitioner argued that, while conceding transferee liability up to the value of the property transferred to her from the decedent's estate, she was not liable for interest on that amount running from the estate tax return's due date. She also contended that, because all significant events occurred in New Jersey, despite the fact that she resided in Florida when she filed her petition, the applicable precedent was that of the Third, rather than the Eleventh, Circuit.

(Of course, she made the latter argument because the Eleventh Circuit in Baptiste v. Commissioner held in the government's favor on that issue while the Third Circuit in Poinier, although a gift tax case, would at least arguably cause a court to rule in her favor.)

Keywords: Saigh, transferee liability, estate tax, Baptiste, Poinier