Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined that petitioner is liable as a transferee of BGF Corporation (BGF) for deficiencies in Federal income taxes and an addition to tax, plus interest as provided by law, determined to be due by BGF, as follows:
Taxable Addition to Tax Year Ended Deficiency Section 6653(a)1 2/28/75 ....... $ 673...
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