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(1) Whether the respective petitioners failed to report
income from illegally received money or property in the taxable
years 1982 and 1983;5
(2) whether the respective petitioners are liable for
additions to tax for fraud under section 6653(b)(1) and (2) for
the years 1982 and 1983;6 and
(3) whether the respective petitioners are liable for the
addition to tax under section 6661 for 1982 and 1983.
FINDINGS OF FACT
Some of the facts have been stipulated pursuant to Rule 91.
The parties' stipulations of fact are incorporated herein by
reference and are found as facts in the instant cases. At the
time their respective petitions were filed in the instant cases,
all petitioners resided in Pennsylvania.
4(...continued)
settlement in which Ryan has conceded the issues presented in his
notice of deficiency, with the provision that the amounts of
unreported income are to be adjusted on the basis of this Court's
opinion as to the amounts of income received by the other
petitioners. Such an adjustment is necessary because of
respondent's protective position asserting that certain items of
income should be attributed to more than one petitioner.
5 Each petitioner's liability for self-employment tax will be
a computational adjustment dependent on the outcome of this
issue. Petitioners do not argue against the application to them
of the self-employment tax per se, but that they did not receive
the underlying unreported income.
6 Resolution of this issue will determine whether the period
of limitations under sec. 6501 has expired.
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