Memorandum Findings of Fact and Opinion
SMITH, Judge:
The proceeding in Docket No. 112270, Estate of Arthur Zellerbach, deceased, contests a determination of deficiency in estate tax by the respondent in the amount of $55,889.33. The petitioners in Docket Nos. 112267, 112268 and 112269 are transferees of the estate of Arthur Zellerbach. Each admits that he or she is liable as a transferee for the full amount of the deficiency which may be redetermined against...
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