Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in Duro Engineering and Mfg. Co.'s Federal corporation income tax for the taxable years ended October 31, 1967 and August 23, 1968 of $31,250.38 and $1,565.62, respectively. The corporation has since dissolved. On a theory of transferee liability, respondent asserts that petitioner Bernard Miller
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