Memorandum Findings of Fact and Opinion
EKMAN, Judge:
Respondent determined that petitioner was liable as a transferee of Donald Peppers and Barbara Jean Peppers. The liabilities for income tax and additions to tax of Donald Peppers and Barbara Jean Peppers were litigated before this Court and a Memorandum Opinion deciding that case was filed today. See Docket No. 9175-78, Peppers v. Commissioner,...
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