Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined, pursuant to section 6901, that petitioner is liable, as a transferee of property, for a deficiency in the 1982 Federal income tax of the transferor Mr. Marvin A. Rivers. (Except as otherwise indicated, all section references are to the Internal Revenue Code, as amended.) The issue for decision is whether, for purposes of section 6901, respondent has met his burden of proving that...
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