BLACK, Judge:
The Commissioner determined deficiencies in the excess profits tax of KQV Broadcasting Co., transferor of $1,236.81 for the calendar year 1944 and $32,421.17 for the period January 1 to February 28, 1945. In a statement attached to the deficiency notice the Commissioner stated, among other things, as follows:
The records of this office indicate that the assets of KQV Broadcasting...
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