Memorandum Findings of Fact and Opinion
IRWIN, Judge:
By statutory notice dated December 4, 1979, respondent determined that petitioner, as transferee of the assets of Robert G. Cope and Allene D. Cope, is liable for deficiencies in Federal income taxes and additions thereto in the following amounts:
Additions to Tax Sec. Sec. Year Deficiency 6653(a)
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