FINDINGS OF FACT AND CONCLUSIONS OF LAW
KATZ, District Judge.
1. On August 23, 1988, Anthony W. Borzillo, Jr. died.
2. Anthony Borzillo (the taxpayer), filed Federal income tax returns (Form 1040) for the years 1985 through 1987 reporting Federal income tax liabilities which he failed to pay.
3. As a result, the IRS made assessments against Anthony Borzillo for Federal income tax liabilities totalling $44,568.00.
4. Although...
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