Memorandum Findings of Fact and Opinion
PARKER, Judge:
In these consolidated cases, respondent determined a deficiency of $374,503.47 in the Federal estate tax of the Estate of Francis M. Ronk, Jr., who died in 1980. With regard to this $374,503.47 deficiency determined against the estate, respondent has also determined transferee liability against the Huntington National Bank of Columbus, Ohio in the amount of $350,179.98.
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