Laura A. Loveland Espinosa - Page 27




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          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.                          




















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