Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
In this proceeding petitioner, as transferee, contests respondent's determination of the liability of Atlantic Paper Company, a corporation, for taxes for the calendar years 1941 and 1942. Deficiencies of the corporation were determined as follows:
1941 1942 Income Tax .................. $5,650.21 ......... Declared Value Excess Profits...
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