FEATHERSTON, Judge:
Respondent determined in docket No. 28216-84 that petitioner is liable to the extent of $300,000 as transferee of Joseph F. Collins, deceased. Respondent also determined in docket No. 26148-84 a deficiency in the amount of $93,779 in petitioner's 1983 income tax together with additions to tax in the amount of $9,193 under section 6651(a)(1),
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