James E. Griffin and Katrina F. Griffin, Transferees - Page 2

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          1992, in the amount of $87,516, plus interest as provided by                
          law.1  Respondent determined, and petitioners concede, for the              
          purposes of this proceeding, that Mr. Fisher's unpaid 1991 and              
          1992 deficiencies and additions to tax are:                                 

          Addition to Tax                                                             
          Year        Deficiency          Sec. 6663                                   
          1991         $52,165             $40,865                                    
          1992          30,771              23,078                                    

               The issue for decision is whether petitioners are liable as            
          the transferees of assets of Mr. Fisher under section 6901,2 and,           
          if so, the amount of such liability.                                        

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Tallahassee, Florida, at the time they               
          filed their petition.  Petitioners were married to each other               
          throughout the period relevant to this case.  Mrs. Griffin and              
          Mr. Fisher are sister and brother.                                          

               1The notice of transferee liability, issued to petitioners             
          on July 7, 1994, determined a liability of $84,467.  In an                  
          amended answer, respondent increased the amount of transferee               
          liability asserted against petitioners to $87,516.                          
               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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