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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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