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JANPOL v. COMMISSIONER

Docket Nos. 5586-92, 5587-92.

101 T.C. 518 (1993)

ARTHUR S. JANPOL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT DONALD BERLIN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 7, 1993.

Attorney(s) appearing for the Case

John N. Lieuwen and Patricia Tucker, for petitioners.

Thomas F. Eagan, for respondent.

COHEN, Judge:

Respondent determined deficiencies against petitioners individually and as transferees of Art Janpol Volkswagen, Inc. (AJVW), as follows:

Docket No. 5586-92

              Transferee liability                   Deficiency

                Sec.         Sec.         Sec.          Sec.        Sec.
    Year      4975(a)      6651(a)(1)    4975(a)   ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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