Jean A. Stanko - Page 14

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          ended on June 21, 1985, and that there were deficiencies in his             
          income tax for 1984 and 1985.                                               
               Stanko did not appear when his case was called from the                
          calendar for this Court's Denver, Colorado, trial session on                
          February 8, 1993.  The Commissioner moved to dismiss for lack of            
          prosecution.  We granted the motion.  Stanko v. Commissioner,               
          T.C. Memo. 1993-513.  We held that Stanko was liable, as the                
          transferee of assets of Stanko Packing, for a deficiency of                 
          $1,324,964 and for additions to tax under sections 6651(a),                 
          6653(a)(1) and (2), and 6655.  We also held that Stanko was                 
          liable for deficiencies of $961,134 for 1984 and $9,611 for 1985            
          and for additions to tax under sections 6651(a), 6653(a)(1) and             
          (2), and 6654.  On January 10, 1994, we entered a decision in               
          that case.  Stanko appealed to the U.S. Court of Appeals for the            
          Ninth Circuit.  On November 1, 1994, that court affirmed our                
          decision.  Stanko v. Commissioner, 42 F.3d 1402 (9th Cir. 1994).            
          Our decision in that case is final.                                         
               On February 18, 1994, the Commissioner assessed income tax             
          liability against Stanko as a transferee of Stanko Packing for              
          its tax year ending June 21, 1985.  No payments have been made              
          towards Stanko's transferee liability.  Respondent has found no             
          assets of Stanko and has received no response from Stanko about             
          his transferee liability.                                                   








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