MEMORANDUM OPINION
JACOBS, Judge:
This case was submitted to the Court fully stipulated under Rule 122. Rule references are to the Tax Court Rules of Practice and Procedure. Section references are to the Internal Revenue Code.
On December 22, 1997, respondent issued to Edward Fridovich a notice of transferee liability with respect to assets petitioner received from the Estate of Martin Fridovich (the estate), Deceased (petitioner's father's estate...
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