Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined that the petitioner is liable as a transferee of the assets of the Bankers Development Corporation (hereinafter referred to as Bankers), for deficiencies in surtax under section 102 of the Internal Revenue Code of 1939 for the years ended April 30, 1948 through April 30, 1950, as follows:
Year Ended Section 102 Surtax 4-30-48 ................
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