Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in the Federal income tax of Sunray DX Oil Company and its subsidiaries, and notified petitioner that it was liable for the deficiencies as transferee of the assets of the said corporations:
TYE Deficiency December 31, 1965 ..... $ 14,055 December 31, 1966 ..... 47,806 December 31, 1967 ......
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