Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined that petitioner is liable to the extent of $71,052.63 as transferee of assets of Uranium Drilling Co. for deficiencies in income tax of that company and additions thereto for the years and in amounts as follows:
Addition to Tax (Sec. 6651(a) Year Ended Deficiency IRC 1954) ...
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