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that, once the deficiency is determined, petitioner is liable for
increased interest on an underpayment attributable to a tax-
motivated transaction as defined in section 6621(c). After
concessions,2 the issues remaining for decision are: (1) Whether
petitioner executed a valid consent to extend the period of
limitations for assessment and collection of the taxes and
addition to tax at issue and (2) whether petitioner is entitled
to a credit of $20,400 for the taxable year in issue.
FINDINGS OF FACT
The parties filed a stipulation of facts, a supplemental
stipulation of facts, and a second supplemental stipulation of
facts, each with attached exhibits. The facts reflected therein
are so found and are incorporated herein.
Petitioner Leon S. Malachinski was a resident of Naperville,
Illinois, when the petition herein was filed. Petitioner and
Wynne Malachinski (Wynne) were married in May of 1980. During
the taxable year in issue, they both were physicians. For a
time, they operated a medical practice together. They filed a
1(...continued)
all Rule references are to the Tax Court Rules of Practice and
Procedure.
2 The parties have executed a stipulation of settled issues
wherein they have settled all questions relating to the amount
of, and petitioner’s liability for, the Federal income taxes and
addition to tax and increased interest for the year at issue,
other than the questions set forth above.
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