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WILTZIUS v. COMMISSIONER

Docket Nos. 19235-93, 19344-93.

73 T.C.M. 2243 (1997)

T.C. Memo. 1997-117

Jeff A. Wiltzius, Transferee v. Commissioner. William Robert Waldorf, Transferee v. Commissioner.

United States Tax Court.

Filed March 6, 1997.

Attorney(s) appearing for the Case

Jeff A. Wiltzius, pro se. William Robert Waldorf, pro se. Joanne B. Minsky and Stephen Takeuchi, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that petitioner Jeff A. Wiltzius is liable as a transferee for the unpaid income tax and additions to tax of House of Babes of Fern Park, Inc. (House of Babes), for 1984 and 1985 in the amount of $155,990, and that petitioner William R. Waldorf is liable as a transferee in the amount of $225,319.

We must decide the following issues:

1. Whether petitioners are liable...

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