Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent asserted transferee liability in these consolidated cases against petitioners, as transferees of The Techni-Chem Company (Techni-Chem), for an income tax deficiency of $176,472.52 determined to be due from Techni-Chem for the taxable year ended September 30, 1976. After concessions by the parties the sole question remaining for the Court's determination is whether Techni-Chem's shipment of...
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