TANNENWALD, Judge:
Respondent determined that petitioner Seaboard Coast Line Railroad Co. is liable as successor by merger to Atlantic Coast Line Railroad Co. (hereinafter referred to as ACL) for deficiencies in Federal income tax for the calendar years and in the amounts as follows:
Year Deficiency 1958 ................... $96,311.98 1959 ................... 621,908.52 1960...
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