Memorandum Findings of Fact and Opinion
Findings of Fact
QUEALY, Judge:
This proceeding involves a transferee liability asserted against the petitioner for taxes and penalties due from Charles T. Atkins, 133 Seaward Avenue, San Ysidro, California, transferor. The taxes and penalties which were assessed against the transferor on March 26, 1965 were stated in the notice of transferee liability, as follows:
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