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MANZOLI v. COMMISSIONER

Docket No. 47848-86.

56 T.C.M. 1406 (1989)

T.C. Memo. 1989-94

Leo Manzoli and Mary Ann Manzoli v. Commissioner.

United States Tax Court.

Filed March 13, 1989.

Attorney(s) appearing for the Case

John M. Doukas, Two Center Plaza, Boston, Mass., for the petitioners. Charles W. Maurer, Jr., for the respondent.

Supplemental Memorandum Opinion

COHEN, Judge:

On July 18, 1988, the Court filed its Memorandum Findings of Fact and Opinion, [Dec. 44,889(M)] T.C. Memo. 1988-299, in which we sustained, with some adjustments, deficiencies determined by respondent with respect to petitioners' Federal income taxes for 1977 and 1978, and we sustained an addition to tax for fraud against petitioner Leo Manzoli for 1978 on the ground of collateral...

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