Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined transferee liability under section 6901 (as a result of transfers of assets on September 27, 1981) against Margie Reed Harper (petitioner) in the amount of $658,360, plus interest, for unpaid 1978, 1979, 1980, and 1981 Federal income taxes, and additions to tax, due from petitioner's former husband, Rodney W. Reed (Mr. Reed).
All section references are to the Internal Revenue...
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