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CASANOVA CO. v. COMMISSIONER

Docket No. 25468-84.

87 T.C. 214 (1986)

CASANOVA COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 28, 1986.

Attorney(s) appearing for the Case

Alan F. Segal, for the petitioner.

Andrew P. Fradkin and Thomas J. Kane, for the respondent.

OPINION

KÖRNER, Judge:

Respondent determined that petitioner was liable for a deficiency of $172,500 in income tax required to be withheld for the calendar year ending December 31, 1980, together with additions to tax under section 6653(a)1 in the amount of $8,625, and a further addition to tax under section 6656 in the amount of $8,625. The issues presented are:

(1) Whether petitioner was required to withhold...

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