OPINION
FORRESTER, Judge:
In docket No. 3833-69, respondent has determined deficiencies in petitioner's income taxes of $10,711.27 and $12,162.28 for the taxable years ending in 1965 and 1966, respectively. In docket No. 1854-69 respondent has determined that petitioner is liable as transferee of the assets of Kansas Sand Co., Inc. (hereinafter referred to as Sand), for an income tax deficiency of $2,015.38...
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