ATKINS, Judge:
The respondent determined that petitioner is liable, as transferee of assets of the Calvert Distilling Co. (successor by merger to Julius Kessler Distilling Co., Inc.), for a deficiency in income tax for the taxable year ended July 31, 1959, in the amount of $360,466.80. The petitioner concedes that it is liable as transferee for any deficiency properly due, but contests the amount of the deficiency. The only issue for decision is whether liquor...
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