Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent asserted liability against petitioner as transferee of The First State Bank of Walsenburg (hereinafter referred to as State) for the year ending December 31, 1955 and the taxable period from January 26 to November 30, 1958 of $3,985.70 and $1,710.90, respectively. The bases for these assertions were: (a) Allocation of a net operating loss of $16,087.21 incurred by State during the period...
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