OPINION
IRWIN, Judge:
Respondent determined a deficiency in income tax of Neat Laundry, Inc., for the taxable year 1967 in the amount of $75,190.16, and notified petitioners that the following liabilities, constituting their liability as transferees of the assets of the corporation, would be assessed against them:
Docket No. Transferee liability 8178-71 ----------------------- ...
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