SIMPSON, Judge:
The respondent determined that the petitioner was liable as transferee for an addition to tax of Jo-Jud Corporation and interest in the amount of $3,195.29. There is no dispute over the liability of Jo-Jud Corporation for the addition to tax and interest determined by the respondent. The sole issue for decision is whether the petitioner is liable as a transferee for such addition to tax and interest.
FINDINGS OF FACT
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