- 2 - the petition herein, petitioners resided in Austin, Texas. References to petitioner are to Gabriel Gutierrez. The determinations by respondent that gave rise to the present case primarily involved unreported gross receipts from petitioner's law practice and additions to tax for fraud. Before trial respondent conceded that petitioner was not liable for fraud for tax year 1988, and that Mrs. Gutierrez was not liable for fraud for any of the years in issue. After concessions by both parties and before trial, the correct deficiencies for each of the years in issue, 1985 through 1988, were stipulated. The only issues for trial were the additions to tax for fraud for 1986 and 1987, as to petitioner, and/or negligence as to petitioners for all of the years in issue, and additions for substantial understatement for tax years 1986 through 1988. In our opinion filed June 12, 1995, Gutierrez v. Commissioner, T.C. Memo. 1995-252, we accepted the stipulated deficiencies and held that petitioner was not liable for the fraud addition for any of the years in issue. We held both petitioners liable for the additions for negligence and substantial understatement for tax years 1986 and 1987, but not for 1988. Petitioners request this Court to award them reasonable administrative and litigation costs in the amount of $39,675.68. 1(...continued) and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011