- 4 - agreed to the following deficiencies in Federal income taxes and additions to tax: Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b) 6661 6663 1988 $3,115 $2,336 -0- -- 1989 924 693 -- -0- The decision document was forwarded to the Court, and the decision was entered on January 11, 1994. At the ensuing trial session at Detroit on January 31, 1994, the case was not called, nor did petitioners or their attorney appear for trial. Petitioners were thereafter assessed by respondent for income tax deficiencies and additions to tax in accordance with the decision. It appears that no collection was made on the assessed liabilities until petitioners filed their 1994 Federal income tax return. That return reflected an overpayment of 1994 taxes in the amount of $1,727. In lieu of refunding the overpayment to petitioners, respondent applied the $1,727 to petitioners' unpaid 1988 liability. That action by respondent gave rise to the motion presently before the Court. In their motion for leave to file, in which petitioners are pro se, petitioners contend there was fraud on the Court and on the Internal Revenue Service (IRS) in the stipulated decision that was signed by their attorney and counsel for respondent on January 5, 1994. Petitioners correctly allege that they did notPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011