Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies and transferee liabilities as follows:
Petitioner Year Deficiency Sharon K. Pack ......... 1974 $ 1,236.58 1975 246.00 J. Ernest and Mary Ann Talley ...... 1970 1,585.11 1973 12,862.07 1974 401,209.72 ...
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