Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined an estate tax deficiency in the amount of $172,476.76 against the Estate of Thomas Douglas Watson, Jr., petitioner in docket No. 2320-75, and determined that W. Harold Sellers, petitioner in docket No. 2318-75, and Joyce Karbach Watson, petitioner in docket No. 2039-75, were each liable as transferees of the estate for the same amounts. Respondent further determined a gift tax...
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