SATNICK v. COMMISSIONER

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

In these consolidated cases, respondent determined that each petitioner is liable, as a transferee of Hartley Jewelers, Inc., for deficiencies in income tax and additions thereto as follows:

                                Additions to tax     
                           Sec. 6651(a) Sec. 6653(a)
  Year    Income tax        IRC 1954      IRC 1954

  1962 .....

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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