- 4 -
alternatively, for the delinquency addition to tax under section
6651(a) for FYE 1993;
(3) whether respondent is barred by section 6501(a) from
assessing a deficiency against Vortex for FYE 1991;
(4) whether the Zhadanovs received constructive dividends
from Vortex in 1990, 1991, 1992, and 1993 in the amounts
determined by respondent or in any amounts;
(5) whether Mr. Zhadanov was required to include a portion
of his 1993 Social Security benefits in his income for 1993;
(6) whether the Zhadanovs are liable for the fraud penalty
under section 6663, or alternatively, for the accuracy-related
penalty under section 6662(a), for any of the years at issue;
(7) whether respondent is barred by section 6501(a) from
assessing a deficiency against the Zhadanovs for 1990 and 1991;4
(8) whether the additions to tax for fraud proposed against
Mr. Zhadanov violate the Double Jeopardy Clause of the United
States Constitution; and
(9) whether Mrs. Zhadanov is entitled to relief from joint
and several liability under section 6015 for 1990, 1991, and
1992.5
4The Zhadanovs claimed that Form 872, Consent to Extend Time
to Assess Tax, extending the period of limitations to Dec. 31,
1995, for taxable year 1991, is invalid as it was obtained under
duress.
5Petitioners also argue that Mrs. Zhadanov is entitled to
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011