GRIFFITHS v. COMMISSIONER

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a notice of transferee liability, respondent determined that petitioner is liable as a transferee for an income tax deficiency and additions to tax owed by Heartland Erectors, Inc. (Heartland), for the taxable year ending September 30, 1988, as follows:

                            Additions to tax
                            ----------------
                       Sec. ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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