2
section 6651(a) in the amount of $323,806, for negligence under
section 6653(a)(1) and (2) in the amounts of $66,248 and 50
percent of the interest due on $1,295,223, and for failure to pay
corporate estimated income tax under section 6655 in the amount
of $83,203.
After concessions, the issues for decision are:
(1) Whether petitioner is barred by res judicata from
contesting that Stanko Packing's liability for income tax and
additions to tax for 1985 are other than as decided in Stanko v.
Commissioner, T.C. Memo. 1993-513, affd. without published
opinion 42 F.3d 1402 (9th Cir. 1994); and that her former
husband, Rudy Stanko (Stanko), is liable as a transferee of
Stanko Packing for its income tax and additions to tax for 1985.
We hold that she is.
(2) Whether, and if so the extent to which, petitioner is
liable under Nebraska law for the 1985 income tax and additions
to tax of Stanko Packing Co. as a successor transferee of its
assets. We hold that she is liable for the amount of 1985 income
tax and additions to tax of Stanko Packing stipulated by the
parties.
(3) Whether the value of the Packerland note when Stanko
transferred it to petitioner was $2,806,979 as respondent
contends; $501,240 as petitioner contends; or some other amount.
We hold that the value was $2,806,979.
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