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other court, and this opinion shall not be cited as precedent for
any other case.
In a notice of deficiency issued to petitioner on September
10, 2004, respondent determined deficiencies as follows:
Year Amount
1992 $14,227
1993 13,146
1994 9,856
Petitioner does not challenge the amount of the deficiency
for any of the years in issue. Instead, petitioner claims relief
from the deficiency for each year under section 6015.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Delaware.
The circumstances surrounding the determinations of the
above-referenced deficiencies are summarized in the following
excerpt taken from United States v. Gricco, 277 F.3d 339, 346-348
(3d Cir. 2002):
From 1990 to 1994, Anthony Gricco was the regional
manager for private companies that contracted with the
Philadelphia Parking Authority to operate the parking
facilities at the Philadelphia International Airport.
Gricco was responsible for the general operation of the
facilities, including the hiring of employees and the
collection of parking fees. Michael McCardell,
Gricco’s brother-in-law, was Gricco’s chief assistant.
McCardell oversaw the day-to-day activities of the
tollbooths and picked up money from the cashiers at the
end of their shifts.
The parking facilities at the airport used
automated ticket machines as well as cashiers. Upon
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