- 60 -
If petitioner and Mr. Korchak were to use all of the assets
owned at the time of the trial, they would be unable to pay even
the $2 million of the liability for their taxable year 1982 that,
at a minimum, the parties agree existed at that time. And they
would be left with no assets to pay the balance of that liabil-
ity, including the interest as provided by law that continues to
accrue and that causes that liability to continue to increase.
All that petitioner and Mr. Korchak would be left with to pay the
balance of the 1982 total liability, as well as all of their
basic reasonable living expenses,32 would be petitioner’s annual
salary of $115,000 and Mr. Korchak’s annual salary of $90,000
that they were receiving at the time of the trial.33 Of course,
those salaries would be subject to Federal and State income taxes
and Social Security taxes, as required by law. Moreover, as of
the time of the trial, petitioner intended to retire in 2007 at
age 70.34
32The basic reasonable living expenses of petitioner and Mr.
Korchak include the expenses with respect to the $139,000 of
liabilities to which their residence that petitioner owned at the
time of the trial was subject.
33During 2004, the year before the trial took place, in
addition to the respective salaries of petitioner and Mr.
Korchak, they received other income from various sources totaling
$60,003. The record does not disclose how much, if any, income
from such sources petitioner and Mr. Korchak expect to receive
after 2004.
34Although Mr. Korchak testified that as of the time of the
trial he had no intention of retiring, we note that he was 71
years old at that time.
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