Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The Commissioner determined a deficiency in the Federal income taxes of J & D, Inc. (hereinafter referred to as J & D) for the fiscal year ending February 28, 1967, in the amount of $23,426.69. J & D was merged into Afton Builders, Inc. (hereinafter referred to as Afton Builders) on January 11, 1968. The petition herein was filed by Afton Builders, as successor to J & D, on July 6, 1970...
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