Jean A. Stanko - Page 2

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          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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