Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined that the petitioners are liable as transferees for income taxes of Edwin S. Neely, deceased, for 1944 in the amount of $585.63, plus interest. The only issue is whether the Commissioner has shown transferee liability. The facts have been stipulated.
[The Facts]
Edwin S. Neely, brother of Eleanor, died on January 2, 1946, while residing in Pittsburgh, Pennsylvania. He...
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