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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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