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Background
Petitioner and his then-wife, Betsy Grossman (hereinafter
sometimes referred to as Betsy), filed joint tax returns for 1985
and 1986. Respondent issued a joint notice of deficiency to
petitioner and Betsy for 1985 and several other years, and
another joint notice of deficiency for 1986. Petitioner and
Betsy filed separate petitions with respect to these notices of
deficiency. Petitioner’s and Betsy’s dockets were consolidated
and set for trial. Shortly before the scheduled trial, the
Commissioner and Betsy reached settlement agreements. These
agreements were filed as stipulations of settled issues.
Petitioner’s dockets were then reset for trial at a later date;
they were tried and briefed; and T.C. Memo. 1996-452 was issued.
Betsy is the only petitioner in docket No. 19143-90. The
stipulation of settled issues in that docket includes the
following:
With respect to all adjustments in the [Commissioner’s]
notice of deficiency for 1986, the parties stipulate to the
following terms of settlement:
1. [Betsy] agrees not to further contest [the
Commissioner’s] determination that, during taxable year
1986, [Betsy] and her husband, Robert D. Grossman, Jr.,
received additional taxable income in the form of personal
travel expenses paid by Markette Corporation in the amount
of $11,660.00 which was not reported on the joint income tax
return filed by [Betsy] and her husband for that year.
* * * * * * *
3. In the event it is established or agreed by the
parties in Robert D. Grossman, Jr.’s, Tax Court case, Docket
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Last modified: May 25, 2011