Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The Commissioner determined that the petitioner is liable as a transferee of assets of a corporation named 84 Woodbine Street Realty Corp., for a deficiency in the income tax of said corporation for its taxable year January 1, 1958, to August 21, 1958, in the amount of $23,481.43, plus interest as provided by law.
The sole issue is whether the petitioner is so liable.
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