Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined deficiencies in the income tax of petitioner's transferor in the amount of $5,087.44 for the taxable year 1962 and in the amount of $170,390.61 for the taxable period January 1, 1965 to November 17, 1965.
This proceeding involves the liability of petitioner as transferee of assets of the transferor.
Certain concessions have been made by the parties, and the only remaining...
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