Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding seeks a redetermination of a deficiency for 1939 of $25,946.33 in income tax, together with penalty of $6,486.58, against petitioner as transferee.
The broad issue relates to petitioner's liability as transferee of her husband, who executed an assignment of his interest in a judgment against his former employer on a salary contract. The assignment was executed in 1935 and payment...
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