Gumm

933 F.2d 1014 Unpublished Disposition NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Nancy J. GUMM, Ellen Gumm Bailey, f.k.a., Ellen Gumm Reuben, Petitioner/Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent/Appellee. No. 90-70100. United States Court of Appeals, Ninth Circuit. Submitted April 12, 1991. * Decided May 29, 1991. Before PREGERSON, NOONAN and DAVID R. THOMPSON, Circuit Judges. 1 MEMORANDUM ** 2 The tax court held Ellen Gumm Bailey liable for the federal estate tax deficiency of the estate of Martha O'Hair Kirsten. The tax court based liability on section 6901 of the Internal Revenue Code of 1954, which provides for the liability of a transferee of estate property if recovery could be had from a transferee under state law. Bailey contests this application of transferee liability. She contends liability cannot attach because the transfer of property to her did not render the estate insolvent, and the Commissioner of Internal Revenue (the…