Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined transferee liability against petitioner as follows:
Addition Income to Tax Period Tax Sec. 291(a) 12/1/49—11/30/50 ....... $ 15,966.98 $ 0.00 12/1/50— 8/31/51 ....... 158,087.96 15,808.80 ...
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