OPINION.
MURDOCK, Judge:
The Commissioner notified the petitioner that it was liable as a transferee for unjust enrichment tax of the General Sports Mfg. Co. for the fiscal year ended October 31, 1936. The deficiency is in the amount of $1,116.98 and was imposed under section 501 (a) (2) of the Revenue Act of 1936. The Commissioner has
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