- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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