Jeff A. Wiltzius, Transferee - Page 2

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          and additions to tax of House of Babes of Fern Park, Inc. (House             
          of Babes), for 1984 and 1985 in the amount of $155,990, and that             
          petitioner William R. Waldorf is liable as a transferee in the               
          amount of $225,319.                                                          
               We must decide the following issues:                                    
               1.   Whether petitioners are liable as transferees for the              
          1984 and 1985 income tax and additions to tax of House of Babes.             
          We hold they are;                                                            
               2.   whether Wiltzius' and Waldorf's interests in a note                
          from the buyer of House of Babes are worth $23,376.15 and                    
          $34,783, as petitioners contend; $118,125 and $170,625, as                   
          respondent contends; or some other amount.  We hold that their               
          interests in the note are worth $88,593.75 and $127,968.75,                  
          respectively;                                                                
               3.   whether Wiltzius' plea agreement (in which he pled                 
          guilty to filing false income tax returns for 1984 and 1985 and              
          agreed to pay $11,329.94 in restitution) limits his liability as             
          a transferee for House of Babes' income taxes for 1984 and 1985.             
          We hold that it does not;                                                    
               4.   whether the doctrines of res judicata, collateral                  
          estoppel, and equitable estoppel bar respondent from assessing               
          tax against petitioners as transferees of House of Babes for 1984            
          and 1985.  We hold that they do not;                                         







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