HALL, Judge:
Respondent determined that petitioner is liable as a transferee for a deficiency of $74,097 determined against the Multi-Colortype Co. for its taxable year 1968.
The issues to be decided are:
(1) Whether all or any of the Multi-Colortype Co.'s advances in July 1964 and September 1967 to its wholly owned subsidiary represent capital contributions rather than loans; and
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