MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner is liable as a successor transferee for the 1985 income tax and additions to tax owed by Stanko Packing Co., Inc. (Stanko Packing), as follows: An income tax deficiency in the amount of $1,324,964, and additions to tax for failure to file under section 6651(a) in the amount of $323,806, for negligence under section 6653(a)(1) and (2) in the amounts of $66,248 and...
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