T.C. Memo. 2006-17
UNITED STATES TAX COURT
MICHAEL R. MOTSKO, Petitioner, AND CHERYL MANNS, Intervenor v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4624-03. Filed February 2, 2006.
Peter B. Brautigam and Michael Jungeris, for petitioner.
Cheryl Manns, pro se.
Julie L. Payne, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: Michael Motsko is a skilled mechanic who
runs a trucking company and repair shop in Fairbanks, Alaska.
His estranged wife used to keep the books, but she was less than
honest in preparing their taxes and ended up serving time for
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