Memorandum Opinion
FAY, Judge:
Respondent determined that petitioner, as a transferee of assets, is liable for personal holding company tax deficiencies in the transferor's Federal income taxes of $5,956 and $4,051 for the transferor's taxable years ending July 31, 1974, and July 31, 1975, respectively. Since petitioner concedes that it is a transferee within the meaning of section 6901,
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