OPINION
BRUCE, Judge:
Respondent determined a deficiency in the estate tax of the Estate of Viola F. Saia in the amount of $10,217.43, and asserted transferee liability for the amount against the petitioner Seredo J. Saia as transferee and beneficiary of the assets of Viola's estate. Seredo filed separate petitions with this Court contesting respondent's determinations — one as executor of Viola's estate, and one in his individual capacity...
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