Supplemental Memorandum Findings of Fact and Opinion
WILBUR, Judge:
The United States Court of Appeals for the Eleventh Circuit remanded this case for us to reconsider whether certain transactions constitute "retransfers" by petitioner-transferee to the transferor so as to vitiate petitioner's transferee liability. Eyler v. Commissioner [85-1 USTC ¶ 9407],
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