Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent has asserted that the petitioner, Alan Foster, is liable as transferee of the assets of Clesco, Inc. (Ohio), against which respondent has determined the following income tax deficiencies:
Taxable Year Ended Deficiency June 30, 1958............. $18,496.60 June 30, 1959............. 47,060.31 October 31, 1959.......... 110.51
The sole...
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