Debra L. Streck and Donald W. Streck - Page 4

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          to section 6653(a)(1)(A) and (B) for negligence or intentional              
          disregard of rules or regulations for the year 1986; and (5)                
          whether petitioners are liable for the addition to tax pursuant             
          to section 6661 for substantial understatement of income tax                
          liabilities for the years 1983, 1984, and 1985.7                            

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts is incorporated herein by this                     
          reference.  At the time the petition was filed, Mr. Streck was              
          incarcerated at FMC Lexington, Lexington, Kentucky, and Mrs.                
          Streck resided in Cincinnati, Ohio.  Petitioners were married in            
          1981 and remained married at the time of trial.  Petitioners                
          filed joint returns for the years in issue.                                 
               During the early 1980's, Mr. Streck owned and operated                 
          P.G.D., Inc. (P.G.D.), a company which provided trucking                    
          services.  P.G.D. incurred substantial operating losses and, in             
          early 1983, ceased operations.                                              
               During the years 1983 through 1985, Mr. Streck served as a             
          consultant to a group of companies known as the Walsh Cos.                  
          (Walsh), which were headquartered in New Jersey.  These companies           



               7Petitioners appear to have raised other issues at various             
          times in this case.  We need not address these issues since they            
          are either frivolous or were not addressed at trial or on brief             
          by petitioners.                                                             




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