Robert D. Grossman, Jr. - Page 5

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                    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.                                     






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