- 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