Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443(A)(b) of the Internal Revenue Code of 1954, as amended, and Rules 180, 181, and 182.
In a notice of transferee liability dated August 16, 1988, and addressed to Page Family Preservation Trust B, Transferee, 10787 S. Township Road, Canby, Oregon 97013, respondent determined that "the income tax liability of...
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