OPINION.
MURDOCK, Judge:
The Commissioner determined deficiencies of $6,316.80 and $1,459.21 in the income tax of the Manahan Oil Co. for the fiscal years ended June 30, 1940 and 1941. He also determined liabilities against the other three petitioners as transferees. The three individual petitioners concede that they are liable as transferees for any amounts due from the corporation. The latter will be referred to hereinafter as the petitioner.
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