Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax and declared value excess profits tax against Cottage Toll Homes, Inc., transferor of petitioners, as follows:
Declared Value Income Excess Profits Year Tax Tax 1944 .......... $ 411.25 ..... 1945 .......... 142.94 $21.26 1946 .......... 44...
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