In a deficiency notice dated August 25, 1950, the Commissioner of Internal Revenue advised Sadie D. Leary as follows:
You are advised that there will be assessed against you the amount of $1,980.69, income tax, plus interest as provided by law, constituting your liability as transferee of assets of the estate of Timothy A. Leary, deceased, * * *
Petitioner does not contest the tax liability attributed to the estate of Timothy A. Leary, but contests only her...
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