Jeffrey L. Beecroft and Carol Larkin-Beecroft - Page 7

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                    generally denied all of petitioners' allegations of error and                                                                                          
                    facts related thereto.                                                                                                                                 
                              On March 22, 1996, Mr. Lipton met with one of respondent's                                                                                   
                    revenue agents.  At this meeting, Mr. Lipton presented some                                                                                            
                    documents to attempt to substantiate petitioners' entitlement to                                                                                       
                    the disputed deductions.  Following this meeting, the revenue                                                                                          
                    agent concluded that the expenditures had been made, but that                                                                                          
                    petitioners had not shown that the expenditures were business                                                                                          
                    related.                                                                                                                                               
                              The Court called this case for trial in San Francisco,                                                                                       
                    California, on June 3, 1996.  Mr. Lipton appeared on behalf of                                                                                         
                    petitioners, and respondent was represented by her counsel.  The                                                                                       
                    parties' counsel reported to the Court that the case was ready                                                                                         
                    for trial, and the Court set the trial for June 7, 1996.  On                                                                                           
                    June 6, 1996, the parties' counsel appeared before the Court and                                                                                       
                    notified the Court that they had settled their differences.                                                                                            
                    Counsel read the terms of the settlement into the record, and, on                                                                                      
                    October 15, 1996, the Court filed the parties' stipulation of                                                                                          
                    settled issues (Stipulation).  As stated in the Stipulation,                                                                                           
                    petitioners agree to report the $21,025 of wages reported on the                                                                                       
                    Form W-2 issued by EP Management Services, Inc., and they agree                                                                                        
                    that they are liable for an accuracy-related penalty under                                                                                             
                    section 6662(a).  Respondent agrees that petitioners are entitled                                                                                      
                    to a $5,211 prepayment credit for Federal withholding on the                                                                                           
                    wages (including $306 that is attributable to excess Medicare                                                                                          




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