FAY, Judge:
Respondent has determined that petitioner is liable as transferee for the following deficiencies in the income tax of Hartland Hospital, transferor:
Taxable period Deficiency May 1, 1963, to Apr. 30, 1964 ------------------- $7,788.00 May 1, 1964, to Jan. 2, 1965 -------------------- 17,364.00
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