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SCHUSSEL v. COMMISSIONER

Docket No. 30639-15.

149 T.C. 363 (2017)

149 T.C. No. 16

GEORGE SCHUSSEL, TRANSFEREE OF DRIFTWOOD MASSACHUSETTS BUSINESS TRUST, F.K.A. DIGITAL CONSULTING, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 5, 2017.

Attorney(s) appearing for the Case

Francis J. DiMento, for petitioner.

Carina J. Campobasso, for respondent.

OPINION

This transferee liability case is before the Court on petitioner's motion to dismiss his case with prejudice. As explained below, we will deny petitioner's motion.

Background

The following facts are derived from the parties' pleadings and motion papers. Petitioner states in his petition...

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