Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent has asserted against the petitioner transferee liability for a Federal income tax deficiency due from Tussaud's Wax Museums, Inc., transferor, for the taxable year ended February 28, 1963, in the amount of $70,043.23. Since the transferor has paid $96.80 of its liability, there is presently due and owing by the transferor the amount of $69,946.43.
The issue for decision is whether...
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