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MAYORS v. COMMISSIONER

Docket No. 8338-82.

48 T.C.M. 680 (1984)

T.C. Memo. 1984-401

Susan J. Mayors v. Commissioner.

United States Tax Court.

Filed July 31, 1984.

Attorney(s) appearing for the Case

Nicholas DePento, for the petitioner. Miles D. Friedman, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined that petitioner is liable as a transferee of Joseph A. Averna for deficiencies in income tax and additions to tax arising from Averna's 1977 and 1978 taxable years as follows:

  Year             Deficiencies  Additions to Tax

  1977 .........    $15,056.27      $2,329.54
  1978 .........     14,896.07       2,190.24

By amended answer, respondent...

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