Benness M. Richards and Jane Richards - Page 6

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          adjustments.  On December 30, 1986, Mr. DeCastro executed a                 
          stipulated decision on behalf of petitioners that states as                 
          follows:                                                                    
                                      DECISION                                        
                    Pursuant to agreement of the parties in the above-                
               entitled case, it is                                                   
                    ORDERED AND DECIDED:  That there is a deficiency                  
               in income tax due from the petitioners for the taxable                 
               year 1978 in the amount of $23,000.00;                                 
                    That there are no additions to the taxes due from                 
               the petitioners for the taxable year 1978, under the                   
               provisions of I.R.C. sec. 6653(a); and                                 
                    That there are no additions to the taxes due from                 
               the petitioners for the taxable year 1978, under the                   
               provisions of I.R.C. sec. 6621(d).                                     
          On the same date, Mr. DeCastro mailed a check to Mr. McWade,                
          signed by petitioners and made payable to the IRS in the amount             
          of $53,571, representing $23,000 in tax and $30,571 in interest.            
          Mr. McWade executed the stipulated decision on April 27, 1987,              
          and mailed the document to the Court.                                       
               On March 30, 1987, Mr. McWade filed a Motion to Sever                  
          petitioners' case from docket No. 17445-82.  Shortly thereafter,            
          the Court granted the motion, severed petitioners' case from                
          docket No. 17445-82, and assigned the case docket No. 8922-87.              
          On May 8, 1987, the Court entered the parties' stipulated                   
          decision as described above in docket No. 8922-87.                          








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