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(2) Whether petitioners for taxable years ended 1984
through 1986 and petitioner Henry Gherman for taxable years ended
1987 and 1988 are liable for additions to tax under section
6653(a)(1) or (a)(1)(A). We hold that they are, but subject to
the relief provisions of section 6013(e).
(3) Whether petitioners for taxable years ended 1984
through 1986 and petitioner Henry Gherman for taxable years ended
1987 and 1988 are liable for additions to tax under section
6653(a)(1)(B) or (a)(2). We hold that they are, but subject to
the relief provisions of section 6013(e).
(4) Whether petitioners for taxable years ended 1984
through 1986 and petitioner Henry Gherman for taxable years 1987
and 1988 are liable for additions to tax under section 6661. We
hold that they are, but subject to the relief provisions of
section 6013(e).
(5) Whether petitioner Henry Gherman is liable for an
addition to tax under section 6651(a)(1) for taxable year ended
1988. We hold that he is.
(6) Whether petitioner Joan Walters is entitled to innocent
spouse relief under section 6013(e) for taxable years ended 1984
through 1986. We hold that she is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and accompanying exhibits are incorporated
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