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MANZOLI v. C.I.R.

No. 89-1607.

904 F.2d 101 (1990)

Leo MANZOLI and Mary Ann Manzoli, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided May 22, 1990.

Attorney(s) appearing for the Case

Ronald J. McDougald, Boston, Mass., was on brief for petitioners, appellants.

Doris D. Coles, Attorney, Tax Div., Dept. of Justice, with whom Shirley D. Peterson, Asst. Atty. Gen., Washington, D.C., were on brief for respondent, appellee.

Before BREYER, Chief Judge, TORRUELLA and ALDRICH, Circuit Judges.

TORRUELLA, Circuit Judge.

Leo and Mary Ann Manzoli appeal from the Tax Court's decision sustaining tax deficiencies assessed against them by the Commissioner of Internal Revenue ("Commissioner"). The issues are various and will be discussed seriatim.

FACTS

On June 13, 1984, the Grand Jury of the United States District Court for the District of Massachusetts indicted Leo Manzoli and Mary Ann Manzoli for willfully attempting to evade and defeat...

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