Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
These proceedings, consolidated for hearing and opinion, involve respondent's determination of the liability of each petitioner as a transferee of the assets of a trust, Ponce De Leon Groves, Fort Pierce, Florida, for deficiencies in the amounts of $1,280.72 income tax, $4,020.98 declared-value excess profits tax, and $20,161.02 excess profits tax for the fiscal year ended October 31, 1944.
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