- 4 - February 1996, totaling 114 hours, Mittelstedt charged petitioner $34,200. This case was calendared for trial on May 20, 1996, and was reported settled at the calendar call. The parties entered into a closing agreement, signed by petitioner on June 6, 1996. This agreement provided that the dispute would be resolved by using an indirect method of determining taxable income because petitioner's records were "inadequate to determine [the amount of] unearned discount income from various deferred income accounts and the [amount of] bad debts from the various bad debt accounts", and that in subsequent years petitioner would maintain records sufficient to allow its tax return to be audited on a "line-by-line" basis "as the appropriate rules and regulations may require." On June 19, 1996, the parties filed a stipulation with this Court providing that petitioner was liable for deficiencies in income taxes for the taxable years 1991 and 1992 in the amounts of $383,874 and $124,325, respectively. The stipulation further provided that petitioner was not liable for the section 6662(a) penalties for either year. The motion for litigation costs was subsequently filed.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011