Memorandum Opinion
DAWSON, Judge:
Respondent determined that petitioner was liable as a transferee for the following deficiencies in the Federal income taxes of Oharco Liquidating Company:
Year Deficiency 1971 ..................... $171,363.96 1972 ..................... 22,398.64 1973 ..................... 24,000.00 Taxable period 1/1/74 thru 5/31/74 ...... 749.69
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