T.C. Memo. 2001-32
UNITED STATES TAX COURT
EDWARD FRIDOVICH, TRANSFEREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4585-98. Filed February 12, 2001.
Steven C. Greene, for petitioner.
Judith C. Winkler, for respondent.
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
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