Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined against petitioner a liability as transferee of Carl J. Reinecke for deficiencies in his individual income taxes of $3,418.09, $3,243.00 and $3,516.65 for the years 1945, 1946 and 1947, respectively. All issues relative to the propriety of the deficiencies determined against the transferor were conceded by petitioner. The sole question is whether petitioner is liable for these deficiencies...
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