Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
The respondent determined that petitioner Jann M. Alexander was liable as a transferee of Raymond A. Hossbach for a deficiency in income tax for 1975 to the extent of $54,000 plus interest. There is no dispute as to the liability of Raymond A. Hossbach for a deficiency in, or additions to, tax for 1975. Nor has any dispute arisen as to the amount of petitioner's liability if in fact she is liable as...
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