MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN,
Respondent determined that petitioner is liable as a transferee to the extent of $2,044,106, $2,522,944, and $4,356,279 for 1993, 1994, and 1995, respectively, for the Federal income tax liabilities and fraud penalties assessed against Driftwood Massachusetts Business Trust, formerly known as Digital Consulting, Inc. (DCI or corporation). The issues for decision are whether he is...
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