Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a transferee liability against the petitioner in the amount of $24,000 for income tax and additions to tax due and owing by her husband Louis Levy for the years 1945, 1946, and 1947 in an amount in excess of $42,000.
The only question for decision is whether petitioner is liable as a transferee in any amount not exceeding $24,000.
Findings of Fact
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