- 5 -
4. In the event it is determined or agreed by the
parties in Robert D. Grossman, Jr.’s, Tax Court case, Docket
No. 14364-91, 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 deficiencies and additions to tax herein
agreed to by [Betsy] by corresponding amounts.
5. * * * The parties agree to settle the income tax
case for said years [1983, 1984, and 1985] for an assessment
against [Betsy] of 65 percent of the deficiencies determined
under paragraphs 1 through 4, above.
* * * * * * *
7. [The Commissioner] agrees to concede the addition to
tax under I.R.C. �6661 for taxable year 1985.
* * * * * * *
10. When the decision in Docket No. 14364-91 becomes
final, [Betsy] and [the Commissioner] will submit to the
Court a stipulated decision giving effect to the above-
described settlement.
Discussion
Petitioner contends that he is entitled to the benefit of
two of the concessions that the Commissioner made in the
stipulations of settled issues in Betsy’s dockets, as follows:
(1) Thirty-five percent of the 1986 addition to tax
under section 6653(b)(1)(A), stipulation 4 in Betsy’s docket
19143-90; and
(2) All of the 1985 addition to tax under section 6661,
stipulation 7 in Betsy’s docket 14208-91.
These two concessions are hereinafter sometimes collectively
referred to as the claimed concessions.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011