Estate of Georgia M. Spenlinhauer, Deceased, Robert J. Spenlinhauer, Executor, T. C. Memo. 2025-134, filed 12/30/25, shows that an executor must execute, or involve himself in a tax disaster.

I’ll defer to Judge Tamara W. Ashford to explicate how Robert the ex’r both torpedoes the estate and gets himself Section 6901 transferee liability for estate tax plus chops, leaving the MA Uniform Fraudulent Transfer Act  to rope him in.

And he represents himself in Tax Court, notwithstanding the $600K he says he spent to litigate the worth of a 1% interest in a family business he inherited from Mom that wound up selling for $375K.

Execution is everything.