Petitioner Friscia purchased his father-in-law's business in 1962. His wife, petitioner Ragonesi, was designated president of the corporation and remained in that office until May 1, 1973, when petitioner Friscia, who at all times ran the company, became president. The company failed to pay to respondent the employee withholding taxes due for 1973, and notices of deficiency of $3,900.50 were issued against both petitioners. After a hearing, respondent determined that petitioner...
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