- 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 parties
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011