OPINION.
ARUNDELL, Judge:
The Commissioner determined a deficiency of $75,013.35 in the income tax of the American Equities Co. for the year 1936. He also determined that petitioner, International Utilities Corporation, is liable therefor as transferee. The case is submitted upon a stipulation of facts with exhibits attached. The return of the American Equities Co. for 1936 was filed with the collector for the district of Delaware, and that of the...
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