Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency in Miracle Laboratories, Inc.'s income tax for taxable year 1965 of $17,717.01 and an addition to tax of $4,429.25 under section 6651(a).
The sole issue to be decided is whether petitioner Felix H. Rosser is liable for the deficiency and addition to tax as transferee of the assets of Miracle Laboratories, Inc. (hereinafter referred to as Miracle or transferor...
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