Memorandum Findings of Fact and Opinion
WELLS, Judge:
By notice of liability dated December 10, 1985, respondent determined that petitioner was liable as transferee for the tax liability of Roy I. and Madeline P. O'Nan, who had been assessed a deficiency of $177,795.34 for taxable year 1969, and an addition to tax for fraud of $88,897.67 under section 6653(b).
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