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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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