STERRETT, Judge:
The respondent determined a deficiency in Sanders-Thoureen, Inc.'s Federal income tax for the fiscal year ended November 30, 1969, in the amount of $35,511.30. In addition to the substantive issue which gives rise to the deficiency in controversy, this case also presents two procedural issues. These issues are whether petitioner, Gator Oil Co., is the transferee of Sanders-Thoureen, Inc., within the meaning of section 6901, I.R.C. 1954, as...
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