- 3 - Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b) 6661 6663 1988 $9,394 $7,046 $2,349 -- 1989 6,565 -0- -- $4,924 A timely petition was filed on behalf of petitioners by an attorney who is admitted to practice before this Court. At the time the petition was filed, and at the time the subject motion was filed, petitioners were legal residents of the State of Michigan. Subsequent to filing the petition, respondent filed an answer and affirmatively alleged that petitioners were liable for fraud pursuant to sections 6653(b) and 6663, respectively, for the years 1988 and 1989. Counsel for petitioners thereafter filed a reply to the affirmative allegations pursuant to Rule 37. In due course, a notice was issued by this Court calendaring this case for trial at the Court's Detroit, Michigan, trial session commencing on January 31, 1994. On January 5, 1994, counsel for petitioners, John C. Griffin, Jr. (Mr. Griffin), and Mark A. Murdock (petitioner) met with counsel for respondent, Dennis G. Driscoll (Mr. Driscoll), at respondent's offices. Petitioner Juanita D. Murdock was not present at this meeting. At the meeting, the parties reached a basis for settlement of the case. A stipulated decision document was prepared and signed on that date by Mr. Griffin and Mr. Driscoll, counsel for the parties. In that decision, the partiesPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011