These proceedings were brought for a redetermination of a deficiency of $18,274.06 in income tax of Columbia Holding Corporation, petitioner herein, for the period January 1 through March 31, 1944; and for the liability of the other petitioners as transferees. The transferee liability is conceded, and the sole issue for decision is whether the corporation assets were sold by the Columbia Holding Corporation, or whether their sale was made by its former stockholders.
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