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Dixie Van Aernam, pro se.
Michael D. Zima, for respondent.
MEMORANDUM OPINION
HALPERN, Judge: By notice of transferee liability dated
February 7, 1997, respondent claims that petitioner is liable as
a transferee of property of Steven W. Van Aernam (Steven) for
deficiencies in Steven’s income taxes for 1988 through 1990.1
Since respondent believes that, at the time of transfer, the
value of property transferred by Steven to petitioner was
$15,000, respondent limits his claim to that amount, less $10
paid by petitioner for the property, plus interest. The sole
issue for decision is whether petitioner is liable in the amount
of respondent’s claim as a transferee of property of Steven.
Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference. We need find few facts in addition to
those stipulated and will not, therefore, separately set forth
our findings of fact. We will make additional findings of fact
1 Respondent determined deficiencies, additions to tax, and
penalties totaling $50,539 with respect to Steven W. Van Aernam’s
(Steven’s) Federal income tax liabilities for such years.
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