- 27 - 1985. The net deficiencies stated in the notice of transferee liability, which petitioner’s evidence falls short of disproving, are thus more than adequate to render petitioner liable for the full stipulated value, $53,828.12, of the transferred stock. We need not reach the issue of whether Mr. Espinosa is also liable for the additions to tax set forth in the transferee notice. We therefore conclude that petitioner has failed to sustain her burden of showing that Mr. Espinosa does not currently owe taxes to the IRS in an amount at least equal to the agreed value of the Lidak shares. Hence, we hold that petitioner is liable to the extent of $53,828.12, plus interest thereon in accordance with California and Federal law. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
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