Estate of Kevin J. Lorenz, Deceased, Elizabeth J. Lorenz, Personal Representative and Elizabeth J. Lorenz - Page 2

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                                        MEMORANDUM OPINION                                              
                  COLVIN, Judge:  This matter is before the Court on                                    
            respondent's motions for entry of decision filed in Estate of                               
            Lorenz v. Commissioner, docket No. 12138-96, and in Comet                                   
            Printing, Inc. v. Commissioner, docket No. 12140-96.  Petitioners                           
            filed objections to respondent's motions, and respondent filed                              
            replies to petitioners' responses.  No party requested a hearing,                           
            and we conclude that none is necessary.                                                     
                  When these cases were called for trial, counsel for the                               
            parties reported that they had reached a basis of settlement,                               
            which they stated for the record.  They now ask the Court to                                
            construe the basis of settlement on two points:                                             
                  1.    Whether the fraud penalties for Elizabeth Lorenz and                            
            for the Estate of Kevin J. Lorenz for 1989 and 1990 should both                             
            be computed based on the entire deficiency, as respondent                                   
            contends, or on one-half of the deficiency, as petitioners                                  
            contend.  We hold that they should both be computed based on the                            
            entire deficiency.                                                                          
                  2.    Whether the depreciation deductions for Comet Printing,                         
            Inc., should be increased by $19,432 for 1989 and $22,863 for                               
            1990 from the amounts determined by respondent in the notice of                             
            deficiency.  We hold that they should not.                                                  

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Last modified: May 25, 2011