T.C. Memo. 1996-530
UNITED STATES TAX COURT
JEAN A. STANKO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25200-91. Filed December 2, 1996.
Robert B. Creager and John Stevens Berry, for petitioner.
William R. Davis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioner is
liable as a successor transferee for the 1985 income tax and
additions to tax owed by Stanko Packing Co., Inc. (Stanko
Packing), as follows: An income tax deficiency in the amount of
$1,324,964, and additions to tax for failure to file under
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