OPINION
HAMBLEN, Judge:
This case is before the Court on the parties' cross motions for summary judgment pursuant to Rule 121.
Respondent issued a notice of deficiency (liability) addressed to petitioner as fiduciary and transferee of the Estate of Blanche L. Ewart on June 24, 1983. In the notice of deficiency (liability), respondent determined that petitioner was liable for a deficiency of $14,637.55 and an addition...
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