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MAZZOCCHI BUS CO., INC. v. C.I.R.

No. 93-7311.

14 F.3d 923 (1994)

MAZZOCCHI BUS CO., INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE. Nicholas MAZZOCCHI; Estate of Rose Marie Mazzocchi, Deceased, Mary Mazzocchi, Executrix, v. COMMISSIONER OF INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Decided January 27, 1994.

Attorney(s) appearing for the Case

Douglas R. Eisenberg, Thomas S. Carles, Carles & Eisenberg, Parsippany, NJ, for appellant.

William J. Patton, Michael L. Paup, Gary R. Allen, Richard Farber, Teresa E. McLaughlin, U.S. Dept. of Justice, Tax Div., Washington, DC, for appellee.

Before: BECKER, NYGAARD, and WEIS, Circuit Judges.

Submitted under Third Circuit LAR 34.1(a) December 7, 1993.

OPINION OF THE COURT

BECKER, Circuit Judge.

This appeal is from a decision of the United States Tax Court which upheld the Commissioner's determination of federal income tax deficiencies for the years 1974 through 1979 against Mazzocchi Bus Co., Inc. ("MBC"), a closely-held corporation; Nicholas Mazzocchi ("Mazzocchi"), its controlling shareholder...

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