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Background
On September 23, 1994, respondent issued a notice of defi-
ciency (notice) to petitioners that determined certain deficien-
cies in, additions to, and accuracy-related penalties on their
Federal income tax (tax) for 1988, 1989, and 1990. Respondent
determined in the notice, inter alia, that petitioners received a
constructive dividend (constructive dividend) during each of the
years 1989 and 1990 from an entity called East Oregon Cattle
Company (EOCC) in an amount equal to the fair rental value of a
house located on property in Jackson County, Oregon (Modoc
property), which respondent determined EOCC owned and in which
petitioners lived without paying rent during each of those years.
This case was calendared for trial at the Court's trial
session in Portland, Oregon, that began on October 2, 1995. On
October 4, 1995, the parties submitted to the Court a stipulated
decision document (stipulated decision document) that was signed
by counsel for respondent and by petitioners, who were not at
that time represented by counsel, and that reflected the agree-
ment of the parties as to the amounts, if any, of petitioners'
deficiencies in, additions to, and accuracy-related penalties on
their tax for the years at issue. On October 16, 1995, the Court
entered a decision in this case pursuant to the agreement of the
parties as reflected in the stipulated decision document.
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Last modified: May 25, 2011