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Jan. 31, 1990 32,851
The notice of deficiency includes an explanation of the
adjustments that states in pertinent part:
The cash receipts and disbursements method of
accounting you used to keep your books and records for
the January 31, 1989 and January 31, 1990 taxable years
does not clearly reflect income; however, the accrual
method of accounting does clearly reflect your income.
Therefore, your taxable income is increased by
$541,709.00 and $151,782.00, respectively. * * *
Due to the increase in your taxable income for the
taxable year January 31, 1990, you did not incur a net
operating loss in that year. Since you carried net
operating losses of $7,700.00 and $10,076.00 back to
the January 31, 1988 and January 31, 1989 tax returns,
respectively, your taxable income for the years January
31, 1988, and January 31, 1989, is increased $7,700.00
and $10,076.00, respectively.
Petitioner invoked this Court's jurisdiction by filing a
timely petition for redetermination. Respondent filed a timely
answer to the petition.
Following the filing of respondent's answer, counsel for
petitioner moved for (and the Court granted) a stay of
proceedings to permit petitioner to submit an offer-in-compromise
to respondent. One year later, however, counsel for petitioner
filed a motion to withdraw from the case, asserting that both
petitioner and Milward had failed to respond to his
communications. We subsequently granted counsel's motion to
withdraw and restored the case to the general docket for trial or
other disposition.
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