FINDINGS OF FACTS AND CONCLUSIONS OF LAW
CLARKSON S. FISHER, Chief Judge.
This is an action commenced by plaintiff, German Cantillo, pursuant to section 7429 of the Internal Revenue Code of 1954 (the Code) requesting the court to determine the reasonableness of the making and the amount of a termination assessment for the taxable period from January 1 through May 27, 1982. After hearing the testimony offered at trial and reviewing the written evidence, the...
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