The respondent determined a deficiency in income tax of $25,594.12 and a fraud penalty of $12,797.06 against Kay J. Jelwan for the year 1948 and that the petitioner is liable therefor as transferee of Jelwan's assets. The petitioner contests both the determination of the deficiency and penalty against Jelwan and her liability as transferee.
FINDINGS OF FACT.
Parts of the facts have been stipulated and are found as stipulated.
Petitioner is a resident...
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