Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioners challenge respondent's determination for 1943 of a deficiency of $7,775.20 in income tax and a $3,887.60 fraud penalty against their transferor, Thomas Davidoff, now deceased, and transferee liabilities against them as follows:
Deficiency Penalty Total Anna Davidoff ... $5,159.00 $2,541.00 $7,700.00 Earl Davidoff ... 2,012.05 ...
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