Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined that petitioner was liable for $47,282.00 as transferee of the assets of his sister, Yvonne W. Cavanaugh, for unpaid taxes and additions to tax and accrued interest as provided by law of Yvonne W. Cavanaugh for the taxable years 1974 through 1978. The statement attached to the notice of transferee liability showed the unpaid taxes and additions to tax of Yvonne W. Cavanaugh for which...
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