Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent has determined that petitioner is liable as a transferee in respect of the following deficiencies in Paramount Pacific, Inc.'s Federal income tax liability as follows:
Year Deficiency 1957 ............... $1,038,061.35 1958 ............... 14,797.16 1959 ............... 9,379.39 1960 ............... 64,585.83
The sole...
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