Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined transferee liability under section 6901 against Shirley O'Sullivan, Anne Marie O'Sullivan, Nancy C. O'Sullivan, and Frank J. O'Sullivan in the amounts of $4,310, $1,615, $1,615, and $1,615, respectively, plus interest, for unpaid 1983 Federal income taxes, and additions to tax, due from Frank P. O'Sullivan (decedent).
Unless otherwise indicated, all section references are...
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