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VESSIO v. COMMISSIONER

Docket No. 21946-87.

59 T.C.M. 1038 (1990)

T.C. Memo. 1990-327

Joseph Vessio v. Commissioner.

United States Tax Court.

Filed June 27, 1990.

Attorney(s) appearing for the Case

Jared J. Scharf, One N. Broadway, White Plains, N.Y., for the petitioner. George H. Soba, for the respondent.

Supplemental Memorandum Opinion

WELLS, Judge:

The instant case is before us on respondent's motion for reconsideration. In our prior memorandum opinion in the instant case, [Dec. 46,557(M)] T.C. Memo. 1990-218, filed on April 30, 1990 ("prior opinion"), we upheld respondent's deficiency determinations against petitioner, holding that petitioner had failed to carry his burden of proof, but held that respondent had failed...

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