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After consideration of the record herein, the briefs of the
parties, petitioners’ objections to the Special Trial Judge’s
recommended findings of fact and conclusions of law, and
respondent’s reply thereto, we conclude that the recommended
findings of fact and conclusions of law of Special Trial Judge
Carluzzo, which are hereinafter set forth as modified in a number
of minor respects, should be adopted as the report of the Court.
In a notice of deficiency dated November 15, 1991,
respondent determined deficiencies in and additions to the
Federal income taxes of petitioner, as follows:
Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Years Deficiencies6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(2) 6661
1985 $329,911 $164,956 ---- ---- 50% of Int.
$82,478
due on
$305,762
1986 90,590 ---- $52,226 50% of Int. ----
17,409
due on
$69,635
In a separate notice of deficiency, also dated November 15,
1991, respondent determined deficiencies of $329,911 and $90,590
in Martha McHan’s respective 1985 and 1986 Federal income taxes,
which deficiencies are based solely on Martha’s alleged joint
liability under section 6013 for the tax deficiencies determined
against petitioner.
After settlement of some issues, the primary issues for
decision are: (1) Whether petitioners on their 1985, 1986, and
1987 joint Federal income tax returns underreported petitioner’s
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