Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined that petitioner is liable under section 311(a) (1) of the Internal Revenue Code of 1939 as a transferee of assets of Clifford Emond, Sr., or Clifford Emond, Sr., and Evelyn Catoe Emond, husband and wife, for unpaid income taxes for the taxable years ended February 28, 1953, and 1954 of $1,376.44 and $11,910.08, respectively, or a total of $13,286.52, plus interest as provided...
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