OPINION
SCOTT, Judge:
Respondent determined deficiencies in Federal income taxes of Chapman Enterprises, Inc., for the period January 1, 1966, through July 12, 1966, in the amount of $161,013.38 and determined a liability as transferees against Jack A. Mele and Erlene W. Mele for this income tax of Chapman Enterprises, Inc., in the amount of $36,683. Respondent also determined a deficiency in the Federal income tax of Jack A. Mele and Erlene W. Mele...
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