The respondent determined that the petitioner, as transferee of the assets of G. W. Startz, as transferee of the assets of Earl M. Clarkson, Jr., was liable for a deficiency of $2,443.22 in the income tax of Clarkson for 1944, and unpaid income tax of $42,436.63 and a deficiency in income tax of $6,288.90 of Clarkson for 1945, or a total for the 2 years of $51,168.75, plus interest as provided by law. The only matters presented by the pleadings for determination are whether...
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