- 3 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011