DRENNEN, Judge:
In docket No. 1786-73, respondent determined that petitioner was liable as a transferee for a deficiency of $38,189.48 in income tax due from College Housing, Inc., for the short taxable period January 1, 1968, through September 30, 1968. In docket No. 9887-74, respondent determined that petitioner was liable as a transferee for the same substantive deficiency of $38,189.48 due from College Housing, Inc., as in docket No. 1786-73 but for the...
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