Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in the income taxes of Penndale, Inc., for the fiscal years ended February 28, 1959, and February 29, 1960, in the respective amounts of $31,793.08 and $19,452.55. Petitioner admits being the successor to Penndale, Inc., by merger and change of name and agrees that it is liable as transferee for any deficiency determined herein. The sole issue for decision is whether...
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