Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined transferee liability under section 6901 (as a result of transfers of interests in realty on June 8, 1981) against Eunice G. Tyrell (petitioner) in the amount of $23,000 for unpaid 1979 and 1980 income taxes, and additions to tax, due from petitioner's former spouse, Scott M. Tyrell (Mr. Tyrell). By stipulation, the parties agreed that the market value (on the date of transfer) of...
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