- 9 -
determined that petitioner had unreported receipts of $338,317
for fiscal year 1987 and $259,951 for fiscal year 1988, had
unreported interest income of $990 for fiscal year 1987 and
$5,189 for fiscal year 1988, and was not entitled to carry
forward a net operating loss of $2,341 to fiscal year 1988, and
that petitioner was liable for additions to tax for fraud and
substantial understatement for fiscal years 1987 and 1988.
E. The Stipulation of Facts
On January 20, 1998, respondent, pursuant to Rule 91(f),
moved to compel stipulation and attached a proposed stipulation
of facts and related exhibits. On February 10, 1998,
petitioner's response was filed. In it, petitioner alleged that
respondent's proposed stipulation was based on records that were
obtained from an illegal search and seizure from its office and
objected to these records' being used in this case. On February
12, 1998, we overruled petitioner's objection and ordered
petitioner to supplement its response and respond substantively
to the order to show cause. Petitioner did not do so. On March
4, 1998, we ordered that the facts and evidence stated in
respondent's proposed stipulation of facts be deemed established
for purposes of this case.
Dr. Cole testified for petitioner.
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