Dennis P. and Diana C. Raquet - Page 5

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          income tax liability of $38,782, would have led to the statement            
          of the deficiency as $38,782.                                               
               On February 6, 1989, the parties filed with the Court a                
          Partial Stipulation of Settlement with regard to the Kelsey/Soda            
          Lake Mining issues.  In the Partial Stipulation of Settlement,              
          petitioners agreed to an adjustment of $85,000 for the 1982 tax             
          year with regard to the Kelsey/Soda Lake Mining tax shelter                 
          project.  Additionally, petitioners conceded the addition to tax            
          for overvaluation with respect to the $85,000 adjustment.                   
          Respondent agreed to concede the addition to tax for negligence             
          with regard to the $85,000 adjustment.  Also, petitioners were              
          granted the opportunity to claim a theft loss for substantiated             
          cash out-of-pocket.                                                         
               On October 8, 1992, petitioners' attorneys filed a Motion              
          for Withdrawal of Counsel.  In the motion, petitioners' attorneys           
          state that they have tried "to obtain direction from petitioners            
          concerning a potential settlement of this case.  To date, we have           
          been unable to receive any commitment from petitioner Dennis                
          Raquet and we have received no communication whatsoever from                
          Diana Raquet."3                                                             



          3The Motion for Withdrawal of Counsel also listed peti-                     
          tioners as having separate addresses.  The record is unclear as             
          to when petitioners were married and whether they remain married.           
          The only evidence of petitioners' marriage is that they jointly             
          filed a Federal income tax return for the 1982 tax year.                    




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