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STONE v. COMMISSIONER

Docket No. 25661-81.

49 T.C.M. 314 (1984)

T.C. Memo. 1984-650

Myron I. Stone, Transferee v. Commissioner.

United States Tax Court.

Filed December 17, 1984.

Attorney(s) appearing for the Case

Albert D. Greenfield, 799 Brickell Plaza, Miami, Fla. 33131, for the petitioner. Julian A. Fortuna, for the respondent.

Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined that petitioner is liable to the extent of $120,780.95, as transferee of assets of his parents, in respect of their Federal income tax liabilities for 1958 through 1965. Petitioner does not challenge the deficiencies and additions to tax against the transferors; the only issue is whether he is liable as a transferee pursuant to section 6901, I.R.C. 1954.

Findings of...

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