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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.
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