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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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