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MAZZEI v. COMMISSIONER

Docket Nos. 16702-09, 16779-09.

150 T.C. 138 (2018)

150 T.C. No. 7

CELIA MAZZEI, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ANGELO L. MAZZEI AND MARY E. MAZZEI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 5, 2018.

Attorney(s) appearing for the Case

Lewis Richard Walton and Lewis Richard Walton, Jr., for petitioners.

Erin Kathleen Salel, Kathleen A. Tagni, and Miles B. Fuller, for respondent.

CONTENTS

FINDINGS OF FACT 140

I. WGA's FSC/IRA Program 141

II. Petitioners' Contribution Limits 142

III. Petitioners' Entrance Into WGA's FSC/IRA Program 143

A. Operations Procedure Memorandum 144

B. Commission Agreement 144

C. Services Agreement 144

D. Management Agreement 145

E. Shareholders Agreement 145

F. Compliance Guide 145

IV. Operations...

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