Robert D. Grossman, Jr. - Page 4

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               No. 20526-90, that any of the travel expenses referred to in           
               paragraph 1, above, were incurred primarily for the benefit            
               of Markette Corporation and did not constitute income                  
               reportable on their joint return, [the Commissioner] agrees            
               to reduce the deficiency and additions to tax herein agreed            
               to by [Betsy] by corresponding amounts.                                
                    4. [Betsy] agrees to the imposition of the additions to           
               tax under I.R.C. �� 6653(b)(1)(A) and 6653(b)(1)(B) for 1986           
               in the respective amounts of 65 percent of the amount                  
               calculated under that section on the deficiency as                     
               determined under paragraphs 1 through 3, above, * * * [The             
               Commissioner] concedes the balance of the addition to tax              
               under I.R.C. �6653(b)(1)(A).[4]                                        
                    5. When the decision in Docket No. 20526-90 becomes               
               final, [Betsy] and [the Commissioner] will submit to the               
               Court a stipulated decision giving effect to the above-                
               described settlement.                                                  
               Betsy is the only petitioner in docket No. 14208-91.  The              
          stipulation of settled issues in that docket includes the                   
          following:                                                                  
                    With respect to all adjustments in the [Commissioner’s]           
               notice of deficiencies for 1983, 1984, 1985, 1987 and 1988,            
               the parties stipulate to the following terms of settlement:            
                    1. [Betsy] agrees not to further contest [the                     
               Commissioner’s] determination that, during taxable years               
               1983, 1984, and 1985, [Betsy] and her husband, Robert D.               
               Grossman, Jr., received additional taxable income in the               
               form of personal travel expenses and medical expense                   
               reimbursements paid by Markette Corporation in the                     
               respective total amounts of $19,119.70, $13,452.26 and                 
               $23,069.34 which was not reported on the joint income tax              
               returns filed by [Betsy] and her husband for those years.              
                           *    *    *    *    *    *    *                            


               4    We do not express any view in the instant opinion as to           
          whether the parties’ agreement in Betsy’s docket, regarding the             
          partial concessions of the fraud addition to tax, can be given              
          effect in precisely the form in which the agreement was made.               




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