- 21 - negotiations, or whether he attempted to resolve with Mr. McWade the discrepancy between the $67,972.50 of Kersting interest deductions disallowed by the notice of deficiency and the lower amount of $38,523 alleged by the petition as having been claimed on the return, petitioners did agree to a deficiency substantially less than that determined by respondent. In sum, the stipulated decision that Mr. DeCastro executed on petitioners' behalf is now final, and petitioners have failed to persuade us that the notice of deficiency issued to them is invalid. It follows that we lack jurisdiction to vacate the decision in this case. To reflect the foregoing, An order will be issued denying petitioners' Motion for Leave to File Motion to Vacate Decision.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Last modified: May 25, 2011