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certain adjustments at issue at docket No. 26819-92. On
December 28, 1993, an Order of Dismissal and Decision was entered
in each case. In December 1995, petitioner, through counsel,
filed motions for leave to file motions to vacate decisions,
contending that the petitions were not filed with her authority
or consent. On November 19, 1996, petitioner’s oral motions to
withdraw her motions for leave to file motions to vacate
decisions were granted. Thus, without regard to her claims under
section 6015, the liability of petitioner and Trupin for the
deficiencies for the years in issue was established by decisions
now final.
As a result of the decisions entered against petitioner and
Trupin in 1993, deficiencies, penalties, and additions to tax
were assessed against petitioner and Trupin. (As of June 9,
2003, the balances owing were $764,662.23 for 1982; $2,125,829.90
for 1983; $3,812,646.14 for 1984; $7,923,698.68 for 1985; and
$527,321.23 for 1986.)
Petitioner’s Conduct
In April 1993, 75 pieces of crated material were held in
storage in Pennsylvania in the name of petitioner. The crated
material had been removed from mansions previously owned by
Trupin’s entities and used or intended as residences of
petitioner and Trupin. In April 1993, at Trupin’s request,
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Last modified: May 25, 2011