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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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