This proceeding involves transferee liability for deficiencies in declared value excess-profits tax and excess profits tax for 1945 in the amounts of $369.85 and $5,765.98, respectively, of the Title Abstract Company of Eugene, Oregon. Petitioner concedes liability as a transferee of assets of the corporation. The only issue involving adjustment of the liability as determined by respondent is whether the amount of $5,000 is accruable by the corporation as a loss sustained...
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