Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letters dated April 21, 1977 respondent claimed deficiencies in income taxes against petitioners Edna A. Bear and John L. Bear, jointly and severally, in their capacities as transferees of Brookridge Development Co., Inc. (Brookridge), a liquidated Kansas corporation. The claimed deficiency amounts are $923.66 for Brookridge's taxable year ended December 31, 1970 and...
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