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MAZZOCCHI BUS CO., INC. v. COMMISSIONER

Docket Nos. 36768-86, 36769-86.

59 T.C.M. 845 (1990)

T.C. Memo. 1990-292

Mazzocchi Bus Co., Inc. v. Commissioner. Nicholas Mazzocchi and Estate of Rose Marie Mazzocchi, Deceased, Mary Mazzocchi, Executrix v. Commissioner.

United States Tax Court.

Filed June 12, 1990.

Attorney(s) appearing for the Case

Thomas S. Carles, 570 W. Mt. Pleasant Ave., Livingston, N.J., for the petitioners. Daniel K. O'Brien, Ismael Gonzalez, and Patrick E. Whelan, for the respondent.

Memorandum Opinion

WHALEN, Judge:

These cases are before the Court to decide petitioners' Motion for Partial Summary Judgement and their accompanying Motion for Certification Order for Interlocutory Appeal.

The cases involve two notices of deficiency. In the first, respondent determined the following deficiencies in, and additions to, the Federal income tax of Mazzocchi Bus Co., Inc.:

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