Yvonne E. Thurner - Page 4

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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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