Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined that petitioner was liable as transferee of her husband's assets for deficiencies in his income taxes and fraud penalties as follows:
Income Tax 50% Fraud Year Deficiencies Penalties 1947 .............. $ 3,737.54 $1,868.77 1948 .............. 3,686.24 1,843.12 1949 .............. ...
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