Teresa G. Butner - Page 6
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10-acre estate and drove a sports utility vehicle. Real property
acquired by petitioner and Mr. Butner, including their residence
and two vacant lots, is titled in petitioner's name only.
Vehicles acquired by petitioner and Mr. Butner are titled in
petitioner's name only.
During 1994, 1995, 1998, 1999, and 2000, Mr. Butner, an
attorney who practiced law as a sole practitioner,5 employed
petitioner as a secretary, even though she had no secretarial
training. During 1994,6 1995, 1998, 1999, and 2000, petitioner
received from Mr. Butner secretarial wages of $2,600, $11,060,
$16,952, $17,278, and $16,952, respectively, from which no income
tax was withheld.
On April 24, 1995, a trust fund recovery penalty of
$276,226.86 was assessed against Mr. Butner in connection with
unpaid payroll taxes of Amtruc, Inc., for the last two quarters
of 1992 and the first two quarters of 1993. On October 25, 1999,
a notice of Federal tax lien was filed against Mr. Butner with
respect to that liability.
In 1996, the U.S. Bankruptcy Court for the Western District
5During 1994, 1995, 1998, and 1999, Mr. Butner, who employed
four or five people who were not lawyers in his law practice, did
not make any estimated tax payments with respect to those respec-
tive years, even though he was self-employed.
6During 1994, petitioner also received from Keyport Life
Insurance Co. a gross distribution of $4,250.12, from which
income tax of $91.67 was withheld.
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Last modified: November 10, 2007