MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined that petitioner, as transferee of assets, is liable for $25,297 plus interest for the transferor's Federal income tax deficiency for the year 1993.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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