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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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