- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011