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paid in 1988 in connection with the settlement agreement; (3)
whether petitioners are liable for the addition to tax for
substantial understatement of tax under section 6661 for 1988;
and (4) whether petitioners are liable for the accuracy-related
penalties under section 6662(a) for 1989 and 1990.
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.
Petitioners resided in Brookfield, Wisconsin, at the time
their petition was filed in this case.
William J. Goeden (petitioner) was employed in several
positions by State Central Credit Union (the credit union) from
January 14, 1957, until he resigned on September 15, 1988,
serving as its president since April 1, 1981. Petitioner did not
have a written employment contract with the credit union at any
time during his employment.
On February 29, 1988, at an executive session of the credit
union's board of directors, a majority of the board (by a 4 to 3
vote) passed a resolution authorizing and directing its chairman
to:
(1) Provide written notice to Mr. William J. Goeden,
President of State Central Credit Union, that the Board
may remove him as an officer and director of State
Central Credit Union for violation of applicable law,
the Articles of Incorporation of State Central, the
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