- 10 - claiming he owed less tax than allowed by the law. Second, he defrauded Ms. Zelasko by purporting to make her liable for his taxes. Third, he carried this fraud to the Tax Court when he filed a joint petition with this Court for a redetermination of the deficiency. The fraud upon this Court culminated when the Court entered a decision signed on behalf of Ms. Zelasko, holding her liable for the tax deficiency. The Court of Appeals for the Ninth Circuit vacated the Tax Court’s Decision and held that Ms. Zelasko, under these circumstances, was entitled to a hearing on her allegations. The facts in Toscano are distinguishable from the instant case. Here, petitioner represented himself and negotiated a settlement with respondent. He signed a stipulation of decision which specifically provides for the assessment and collection of statutory interest. We do not find any fraud perpetrated upon this Court. Accordingly, An order will be issued denying petitioner's Motion for Leave to File a Motion to Vacate or Revise the Decision.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011