Memorandum Findings of Fact and Opinion
This proceedings involves deficiencies in income taxes and penalties determined against the estate of Harry F. Reinhardt, deceased, as follows:
Year Deficiency Penalty 1942 .......... $11,953.21 $ 5,976.61 1943 .......... 47,058.22 23,698.61 1944 .......... 31,308.16 15,654.08
The sole issue is whether the petitioner is liable as transferee for unpaid...
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