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memorandum. Accordingly, after concessions by respondent,2 the
only issue for decision is whether the deficiencies, additions to
tax, and increased interest contained in the subject notice of
deficiency were part of prior settlement agreements with
respondent.
There is no stipulation of facts in this case.3 The Court
relies only upon the pleadings, and the testimony and exhibits
admitted at trial. Petitioners were residing in Phoenix,
Arizona, at the time the petition was filed in this case. All
references to petitioner are to Dr. Robert W. Ackerman.
2Respondent in her trial memorandum makes a number of
concessions. She concedes $4,048 of the adjustment to income for
tax year 1981 and $15,801 of the adjustment to income for tax
year 1982, now limiting her adjustments for those years to
$14,653 and $27,667, respectively.
With respect to the asserted additions to tax under sec.
6659, respondent concedes that the addition to tax for the year
1979 is $1,550.40 instead of $6,210, that the addition to tax for
the year 1981 is $4,676.40 instead of $7,550.40, and respondent
concedes that there is no addition to tax due for the year 1982
under sec. 6659.
In the alternative to the additions to tax under sec. 6659,
respondent has asserted additions to tax under sec. 6661 for the
years 1978, 1979, 1981, and 1982. She concedes that in the
alternative to the sec. 6659 additions to tax asserted for the
years 1981 and 1982, the additions to tax under sec. 6661 are
limited to $2,395 and $3,930, respectively.
3Petitioner Robert W. Ackerman refused to agree to any
factual or documentary stipulations.
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