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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