MEMORANDUM
SWINFORD, District Judge.
The record of this case is before the court on the plaintiff's motion for summary judgment. The facts are briefly these. On or about January 16, 1969, a proposed tax deficiency assessment in the amount of $63,569.42 plus a penalty and interest was made by the Internal Revenue Service against the plaintiff, Cowden Manufacturing Company, as transferee of Comanco, Inc., a dissolved corporation. The plaintiff, upon the denial...
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