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VILLANI v. COMMISSIONER

Docket No. 24508-83.

52 T.C.M. 8 (1986)

T.C. Memo. 1986-338

Johanna Trace Villani v. Commissioner.

United States Tax Court.

Filed August 4, 1986.

Attorney(s) appearing for the Case

Johanna Trace Villani, pro se. John E. Becker, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1981 in the amount of $99,900.00 as transferee of assets of her husband Steven John Donahue. The issue we must decide is whether petitioner is liable as a transferee pursuant to section 6901(a)(1)(A).1

Findings of Fact

Petitioner Johanna Trace Villani resided...

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