Memorandum Opinion
WILBUR, Judge:
This case is before the Court on respondent's Motion for Summary Judgment filed January 23, 1979, pursuant to Rule 121, Tax Court Rules of Practice and Procedure. There was no appearance by or on behalf of petitioner at the hearing on March 20, 1979, in Miami, Florida.
Petitioner is transferee of assets of Mrs. Ilda Danzig, her sister, and a statutory notice of liability...
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