- 7 -- 7 - 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 MedicarePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011