Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent has asserted that petitioner is a transferee of Lath Rite Builders, Inc., based on the following deficiencies and additions to tax assessed against Lath Rite:
Year Deficiencies Addition to tax under Sec. 6651(a), I.R.C., 1954 1954 ........ $1,918.90 $479.73 1955 ........ 3,864...
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