JOHN T. STEWART III TRUST v. COMMISSIONER

WILES, Judge:

The respondent has determined that the petitioners are liable, as transferees, for deficiencies in Federal income taxes due from the National Co. of Omaha, transferor, for the taxable years ended October 31, 1962, and October 31, 1965, as follows:

             Year                              Deficiency

         Oct. 31, 1962 ---------------------    $8,148.00
         Oct. 31, 1965 ---------------------   221,927...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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