Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 3

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          sections 6653(a)(1)(A) and (B) or 6661 for that year.  The                  
          stipulated decision includes the parties' stipulation that the              
          deficiency in tax was computed on the assumption that petitioners           
          correctly reported Irving & Co. partnership items on their 1986             
          tax return and that adjustments to petitioners' tax liability for           
          1986 relating to their investment in Irving & Co. would be                  
          resolved in separate partnership level proceedings.  The final              
          paragraph of the stipulation states that, upon entry of decision,           
          petitioners waive the restriction contained in section 6213(a)              
          prohibiting assessment and collection of the deficiency and                 
          statutory interest until the decision of the Court is final.                
               On July 11, 1991, petitioners paid $1,747 to respondent in             
          satisfaction of the deficiency stipulated to in docket No. 11547-           
          90.  Further, on July 18, 1991, petitioners paid $976.38 to                 
          respondent in satisfaction of the interest due on the deficiency.           
          The latter payment resulted in an overpayment of $17.41, which              
          respondent credited to petitioners' tax liability for 1988                  
          pursuant to section 6402(a).                                                
               On April 16, 1993, petitioner, acting as tax matters partner           
          for Irving & Co., filed a timely petition for readjustment with             
          the Court, assigned docket No. 7530-93, seeking readjustment of             
          items set forth in a notice of final partnership administrative             
          adjustment (FPAA) issued to Irving & Co. for its taxable year               
          1986.  On September 12, 1994, the Court entered a decision                  





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