Keener Oil & Gas Co. v. Commissioner

*194OPINION.

Seawell :

In 1922 all the assets of the Akin Oil Co., which had a value greater than the tax and interest here involved, were transferred to petitioner in exchange for certain of petitioner’s stock and an agreement on its part to “ assume and be bound by all the liabilities and .obligations of The Akin Oil Company * * * ”, which *195agreement is contained in resolutions of the parties dated March 14, 1922, set out in the findings of fact.

These facts would apparently render petitioner liable at law and in equity as a transferee of the Akin Oil Co. for any deficiency in its tax for the year…