OPINION AND ORDER
KINNEARY, District Judge.
This matter is before the Court on the United States of America's Petition for Review and the trustee's Cross-Petition for Review of the Referee's order of November 20, 1969.
The bankrupt, Certified Credit Corporation (Credit) merged with Certified Mortgage Corporation (Mortgage) on December 31, 1959. The claim at issue on this appeal arises out of an assessment made by the Internal Revenue Service on June...
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