BENSUADE v. COMMISSIONER

Memorandum Findings of Fact and Opinion

TRAIN, Judge:

Respondent has asserted that petitioner is liable as a transferee of Flomarcy Company, Inc., in the amount of $87,878.22. This determination is based upon deficiencies and an addition to tax determined against Flomarcy Company, Inc., in the years and in the amounts as follows:

                                 Addition to
                                 Tax under
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