MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined that petitioner in his capacity as a fiduciary of the Estate of Marguerite B. Greer (sometimes referred to as the Estate) was personally liable under 31 U.S.C. section 3713(b) (1994) for unpaid estate taxes owing by the Estate in the amount of $32,443, plus interest. Respondent reflected this determination in a notice of liability mailed to petitioner on December 21, 1993.
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