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NAPORANO v. U.S.

Civ. A. No. 93-106 (AJL).

834 F.Supp. 694 (1993)

Joseph F. NAPORANO and Marcia Naporano; Andrew J. Naporano, Jr. and Sharon Naporano, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. New Jersey.

October 1, 1993.

Attorney(s) appearing for the Case

Colin Danzis, Walter J. Fessler, Thomas N. Torzewski, Donald B. Fraser, Jr., Lum, Hoens, Conant, Danzis & Kleinberg, Roseland, NJ, for plaintiffs.

Susan C. Cassell, Asst. U.S. Atty., Newark, NJ and David Blair, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendant.

OPINION

LECHNER, District Judge.

This is an action by plaintiffs Joseph F. Naporano ("Joseph Naporano"), Marcia Naporano, Andrew J. Naporano, Jr. ("Andrew Naporano") and Sharon Naporano (collectively, the "Taxpayers") against defendant United States of America (the "Government") to recover deficiencies assessed to and collected from the Taxpayers by the Internal Revenue Service (the "IRS") for the taxable years

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