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Lawrence F. Ruggiero and Robert Koppelman, for petitioners.1
Cheryl A. McInroy, Elizabeth A. Maresca, and
Steven D. Tillem, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Charles L. Fields and Barbara S. Fields
petitioned the Court to redetermine respondent's determinations
with respect to their 1980 through 1982 taxable years.
Respondent determined deficiencies of $525,389, $243,493, and
$1,365 in their 1980, 1981, and 1982 Federal income taxes,
respectively. Respondent also determined that Mr. Fields was
liable for a: (1) $262,695 addition to his 1980 tax under
section 6653(b), (2) $121,747 addition to his 1981 tax under
section 6653(b), (3) $683 addition to his 1982 tax under section
6653(b)(1), and (4) time-sensitive addition to his 1982 tax under
section 6653(b)(2) with respect to that year's entire deficiency.
Respondent's determinations are reflected in a notice of
deficiency dated May 14, 1987.
1 Mr. Ruggiero and Mr. Koppelman entered the case on
Apr. 17, 1995, and May 22, 1995, respectively. Edward J. Daus,
who prepared the subject petition, withdrew as petitioners'
counsel on June 16, 1988. Paul S. Haar entered the case on
petitioners' behalf on Nov. 21, 1989, but withdrew on Feb. 14,
1990. Mr. Haar also withdrew on Jan. 6, 1993, after he had
reentered the case on May 14, 1990.
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