Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency in income tax for 1948 of $59,247.31 against the Fains and one of $26,726.76 for the same year against the McGahas. The facts have been stipulated.
The petitioners, who were transferees of the assets of another taxpayer, paid taxes of that taxpayer in 1948. The Commissioner contends that the losses, suffered in 1948 as a consequence of the payment of those taxes, represent...
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