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SCHUSSEL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 4050-11.

T.C. Memo. 2013-32

GEORGE SCHUSSEL, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed January 31, 2013.

Attorney(s) appearing for the Case

Francis J. DiMento , for petitioner.

Carina J. Campobasso , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge.

Respondent determined that petitioner is liable as a transferee to the extent of $2,044,106, $2,522,944, and $4,356,279 for 1993, 1994, and 1995, respectively, for the Federal income tax liabilities and fraud penalties assessed against Driftwood Massachusetts Business Trust, formerly known as Digital Consulting, Inc. (DCI or corporation). The issues for decision are whether he is...

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