Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a transferee liability of $307.10 against each petitioner. After concessions by respondent the issue for decision is whether petitioners are liable as transferees of the estate of Ralph A. Emery for the income tax deficiency of the decedent for 1965.
Findings of Fact
Some of the facts have been stipulated and they are so found.
Petitioners are Ruby L. Shimko...
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