Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined an income tax deficiency of $1,406.19 against Wayne Coal Mining Company, herein called Wayne, for the first four months of 1949 and determined that Hillman Coal & Coke Company, herein called Hillman, is liable as a transferee for that deficiency and interest thereon. Hillman concedes that it is liable for any deficiency due from the taxpayer. The issues raised by the petition are whether...
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