MEMORANDUM FINDINGS OF FACT AND OPINION1
SWIFT, Judge:
By notices dated August 6, 2002, respondent determined that petitioners Carrie, Tracy, and Deborah Suchar were liable as transferees relating to their father Richard Suchar's (Richard) Federal income tax liabilities for the years 1995 ($23,278) and 1996 ($20,238), plus penalties and interest.
Based on respondent's determination as to the value of assets transferred...
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