FOSTER, Circuit Judge.
The Commissioner of Internal Revenue assessed deficiencies of income taxes for the year 1921 and 1922 against the Barr-Davis Oil Company of Texas, amounting to $19,228.77. Prior thereto the company had been liquidated and the assets distributed to the stockholders. The commissioner notified petitioners and other stockholders of his intention to assess the deficiencies against them as transferees, under the provisions of section 280 of the Revenue...
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