FINDINGS OF FACT
SIMPSON, Judge:
The respondent has asserted that Eileen J. Moran, the petitioner, is liable for $12,667.78 as transferee of the assets of James J. and Josephine Moran. The liability of the transferors for tax and penalties was decided by this Court in docket No. 69061.
The respondent mailed a notice of transferee liability to the petitioner on May 28, 1964. On August 27, 1964, a petition was filed with this Court requesting...
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