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Background
The record establishes and/or the parties do not dispute the
following facts. Petitioner Yvonne E. Thurner and petitioner
Scott P. Thurner (petitioners) are husband and wife. At the time
the petitions were filed, petitioners resided in Elm Grove,
Wisconsin.
A. Taxable Years 1980 and 1981
Petitioners filed joint Federal income tax returns for 1980
and 1981. Respondent subsequently determined deficiencies of
$351,855 and $512,052 in petitioners’ Federal income taxes for
1980 and 1981, respectively. Respondent also determined that
petitioners were liable for additions to tax for negligence under
section 6653(a) and increased interest under section 6621(c) for
1980 and 1981. Petitioners challenged respondent’s
determinations in a petition filed with the Court at docket No.
8407-87.
In Thurner v. Commissioner, T.C. Memo. 1990-529, we
sustained (with minor adjustments) respondent’s determinations
for 1980 and 1981. The Court entered its decision in docket No.
8407-87 on January 30, 1991, and no appeal was filed.
In June 1991, respondent assessed the deficiencies,
additions to tax, and increased interest as redetermined by the
Court in Thurner v. Commissioner, supra. Shortly thereafter,
respondent began collection activities. Petitioners’ tax
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