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18, 1997, pursuant to Rule 121.1 The issue for decision is
whether the doctrine of res judicata applies so as to preclude
petitioners from litigating the deficiencies determined by
respondent in this Court. Respondent, in the notices of
deficiency, dated June 28, 1990, determined deficiencies and
additions to tax as follows:2
Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1)16653(a)(1)26653(a)(2) 6653(b)(1) 6654 6661
1985 $83,708 $20,927 $4,185 $20,891 --- --- $20,318
1986 846,527 --- 42,326 160,465 --- --- 210,621
1987 467,494 --- 23,375 58,891 --- --- 116,874
1988 1,578,324 74,581 64,916 --- $210,000 $86,230 144,581
1 For 1986 and 1987, sec. 6653(a)(1)(A).
2 For 1986 and 1987, sec. 6653(a)(1)(B).
On September 24, 1990, petitioners filed petitions for a
redetermination of the deficiencies and additions to tax for the
taxable years in issue. Respondent filed answers to the
petitions on November 5, 1990.
On April 9, 1991, petitioners filed a petition in the U.S.
Bankruptcy Court for the Middle District of Georgia. The case
1 All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
2 Docket No. 21394-90 refers to 1985 through 1987, and the
notice of deficiency is asserted against Timothy and Patricia
Brumlik. Docket No. 21393-90 refers to 1988 and the notice of
deficiency is asserted against Timothy Brumlik.
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