Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in the tax liability of S. B. Hamilton, Sr., for the taxable years 1941 to 1945, inclusive, in the amounts of $5,184.18, $6,935.24, $8,796.87, $7,245.38, and $655.13, respectively, plus a 50 per cent fraud penalty for each of the taxable years 1941 to 1944, inclusive, and determined that petitioner was liable for said deficiencies as transferee to the extent of the value...
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