Memorandum Findings of Fact and Opinion
The Commissioner proposed to assess against the petitioner as transferee of the assets of the Old Colony Storage and Warehouse Company, Inc., the amount of $15,459.74, with interest, representing income taxes, excess-profits taxes, personal holding company surtaxes, and penalty due from the transferor for the taxable years of 1936 and 1937.
The sole issue is the petitioner's liability as a transferee of the assets...
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