- 4 - 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’ taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011