MULRONEY, Judge:
In docket Nos. 440-65 and 441-65 respondent determined deficiencies in the 1961 income tax of petitioners Howard R. Ward and Rossford Terminal Warehouse, Inc., in the amounts of $216,656.49 and $145,685.49, respectively (plus negligence penalties which respondent has waived). In docket No. 442-65 and docket No. 443-65 respondent determined transferee liability against the Rossford Terminal Warehouse, Inc., in the amounts of $227,489.31 and...
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