Stanley J. Zaban and Shirley A. Zaban - Page 4

                                        - 4 -4                                        

          for 1989 pursuant to section 6662; (5) whether petitioners are              
          liable for additions to tax for the substantial understatement of           
          tax pursuant to section 6661 for 1986, 1987, and 1988 and for the           
          penalty pursuant to section 6662(b)(2) for 1990; and (6) whether            
          petitioners are liable for the addition to tax for failure to               
          timely file their 1989 joint return pursuant to section 6651(a)(1).         
               All section references are to the Internal Revenue Code as in          
          effect for the years in issue, unless otherwise indicated.  All             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
          Background                                                                  
               Petitioners, husband and wife, resided in Lutherville,                 
          Maryland, at the time they filed their petition.  They were married         
          in 1967 and have one daughter, Nicole.                                      
               Mr. Zaban graduated from college in 1967 and subsequently              
          became involved in illegal gambling and bookmaking activities               
          (described in detail below).  Mrs. Zaban graduated from high school         
          in 1964 and has no college-level education.                                 
               Between 1986 and 1990, Mrs. Zaban was a homemaker and did not          
          work outside of the home.  Mrs. Zaban was the caretaker of                  





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

Last modified: May 25, 2011