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No later than March 5, 1996, respondent's counsel mailed an
agreed form of decision (the form of decision) to petitioner's
counsel for his signature.
On March 29, 1996, the Court entered a decision in this case
(the decision) utilizing the form of decision furnished by the
parties. The decision reflected the parties' agreement that
petitioner's income tax liability for 1988 is as follows:
Deficiency (without taking into consideration
the assessment subsequent to the mailing of
notice of deficiency on April 14, 1995) $24,939.21
Tax paid 24,939.21
* * * * * * *
Deficiency (to be paid) NONE
The decision also reflected the parties' agreement that
petitioner was not liable for any addition to tax under either
section 6651(a) or section 6654(a).
The amount of the deficiency reflected in the decision
(without taking into consideration the assessment subsequent to
the mailing of notice of deficiency on April 14, 1995) was equal
to the tax reported on the filed return.
On April 24, 1996, petitioner filed her motion for costs.
Thereupon, the Court vacated the decision and filed the form of
decision as a stipulation of settlement. See Rule 232(f).
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