Memorandum Findings of Fact and Opinion
HARRON, Judge:
In Docket No. 26663, Don Lee, Incorporated, the Commissioner determined a deficiency in income tax for the year 1946 in the amount of $327.058.74. Most of the deficiency is in tax under section 102, I. R. C. Thomas S. Lee Enterprises, Inc., is the transferee of Don Lee, Incorporated. In Docket No. 26662, Thomas S. Lee Enterprises, Inc., Transferee, the Commissioner has determined that its liability as...
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