SIMPSON, Judge:
The respondent has asserted that the petitioner is liable for $563,170.12 as transferee of the assets of Chicago White Sox, Inc. Such liability arises from a determination of deficiency in the transferor's income tax of $303,109.07 for its taxable year November 1, 1961, to May 31, 1962. The respondent also disallowed a net operating loss carryback from such taxable year to the transferor's taxable year January 1, 1959, to October 31, 1959, and...
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