The Commissioner asserts a liability against petitioner as transferee of the estate of Albert W. Priest, against which the Commissioner determined a deficiency in income tax for the period January 1 to October 11, 1938, in the sum of $1,434.50. The deficiency was determined on March 8, 1944, under the provisions of section 820 of the Revenue Act of 1938 (section 3801 of the Internal Revenue Code), against the estate as a related taxpayer of Itola M. Evans Ransom, a beneficiary...
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