Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined that petitioner is liable, as transferee of the assets of one of its co-trustees, Bernard Gross, in the amount of $82,769 in respect of that trustee's personal Federal income tax liability for 1980. Petitioner does not challenge the deficiencies in and addition to tax against the transferor, but instead challenges the Commissioner's pursuit of it as the transferee of Bernard...
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