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Respondent issued a statutory notice of deficiency on
February 14, 1994, in which deficiencies in income tax and
additions to tax were determined as follows:
Tax Year Ended Deficiency Additions to Tax
Sec. 6653(a) Sec. 6661
July 31, 1988 (TYE 1988) $93,500 $4,675.00 $23,375
July 31, 1989 (TYE 1989) 73,651 3,682.55 20,883
Total 167,151 8,357.55 44,258
The notice of deficiency also made adjustments to
petitioner's fiscal 1990 tax year, although no deficiency was
determined for that year. A petition was filed on May 16, 1994.
At that time, petitioner (or MMC), a California corporation, had
its principal office at 6800 Bayshore Walk, Long Beach,
California.
On June 20, 1994, respondent filed an answer to the
petition. After the case was calendared for trial, but prior to
trial, the parties filed a Stipulation of Settled Issues. A
stipulated Decision was entered by the Court on November 29,
1996, setting forth deficiencies of $6,249 and $5,245, and no
additions to tax, for TYE 1988 and TYE 1989, respectively.
Petitioner thereafter filed its motion for costs. (Petitioner
did not submit a memorandum of points and authorities in support
of its motion for costs.) In accordance with section 7430 and
Rule 232, and pursuant to the Court's Order, the stipulated
Decision was vacated and set aside, and filed as a Stipulation of
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