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RIZZUTO v. U.S.

No. 92 Civ. 1145 (BDP).

889 F.Supp. 698 (1995)

Dennis RIZZUTO and Richard Katz, Plaintiffs, v. UNITED STATES of America, Defendant. UNITED STATES of America, Third Party Plaintiff, v. Edward WEISS and John Treglia, Third Party Defendants.

United States District Court, S.D. New York.

March 18, 1995.

Attorney(s) appearing for the Case

Edward Weiss, Whitestone, NY, pro se.

John J. Gochman, Cronton-on-Hudson, NY, for plaintiffs.

Deborah Yeoh, U.S. Atty.'s Office, New York City, for defendant U.S.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

PARKER, District Judge.

This Memorandum constitutes the findings of fact and conclusions of law of the Court after a bench trial on February 14, 15 and 21, 1995 in which the claims of the United States were tried against Edward Weiss.

1. On February 4, 1991, the Internal Revenue Service (the "IRS"), made an assessment against Richard Katz ("Katz") for a 100-percent penalty pursuant to 26 U.S.C. §...

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