Memorandum Findings of Fact and Opinion
COLVIN, Judge.
Respondent determined that petitioner Marjorie E. Connell, formerly Killian, is liable as transferee of the Estate of Jerry Killian for 1981 income tax in the amount of $14,840.66, plus additions to tax for negligence under section 6653(a)(1) and (2) in the amounts of $742.03 and 50 percent of the interest due on $14,840.66, and increased interest under section 6621(c).
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