FINDINGS OF FACT
TURRENTINE, Chief Judge.
After trial in this matter on December 19, 1982, and after hearing arguments of counsel, the Court makes the following Findings of Fact:
1. On September 13, 1974, the Commissioner of Internal Revenue made an assessment against John W. Spatafore in the amount of $77,829.60, as his liability for the excise tax on wagers imposed by Section 4401(a) of the Internal Revenue Code, 26 U.S.C. § 4401(a), as then...
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