Eddie Cordes, Inc., Transferee - Page 1

                                 T.C. Memo. 2001-265                                  

                               UNITED STATES TAX COURT                                

                    EDDIE CORDES, INC., TRANSFEREE, Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18131-98.                  Filed October 4, 2001.           

               O. Christopher Meyers, for petitioner.                                 
               Gary L. Bloom, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               MARVEL, Judge:  In his notice of liability to Eddie Cordes,            
          Inc., respondent determined that petitioner Eddie Cordes, Inc.,             
          is liable as a transferee for Cordes Finance Corp.’s 1990 Federal           
          income tax deficiency of $1,320,434,1 penalties of $259,058 and             

               1Monetary amounts are rounded to the nearest dollar.                   

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