Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a liability of $52,698.88 against petitioner as alleged transferee of The Koppers Coal Company and representing a deficiency in income tax in that amount determined as due from the alleged transferor for the calendar year 1938. Fourteen issues are framed by the pleadings. These issues, together with the facts found and opinion thereon, will be set out separately hereinafter....
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