SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION*
COLVIN, Judge:
This case is before the Court on petitioner's motion for special leave to file motion to vacate decision and motion to vacate decision.
In a prior opinion issued in this case, we held that petitioner was liable as a transferee for Federal income tax owed for the year ending September 30, 1986, by Napa Investment Corp. (Napa). Merriam v. Commissioner...
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