Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent has determined that LDS, Inc., petitioner, is liable as transferee for income tax deficiencies in the amounts of $2,481 and $305,327 of Glen-Terra, Inc. and subsidiaries for the taxable years ended December 31, 1977, and July 12, 1979, respectively. The parties have resolved certain adjustments and the only one remaining in dispute is an increase, determined by respondent, in the amount...
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