The Commissioner has asserted transferee liability against each of the petitioners in these consolidated proceedings as follows: Jack O. Nutter, $100,000; Jane E. Nutter, $100,000.
The Commissioner has determined that petitioners, each as transferee of an undivided one-half interest in a parcel of land worth $100,000 at the time of transfer, are liable under section 6901, I.R.C. 1954,
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