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therefore did not make any adjustments to Revenue Agent Bacino's
determination regarding deposits from a corporate source.
By notice of deficiency dated June 13, 1997, respondent
determined an increase in petitioners' taxable income in the
amount of $108,310 for 1991 and $133,730 for 1992. Respondent
determined corresponding deficiencies in the amounts of $34,724
and $42,111, respectively, additions to tax under section
6651(a)(1) in the amounts of $8,681 and $6,317, respectively, and
accuracy-related penalties under section 6662(a) in the amounts
of $6,945, and $8,422, respectively.
Petitioners filed a petition with this Court on September 2,
1997. Respondent filed an answer on September 29, 1997. This
case was called from the calendar on March 9, 1998. On that day,
the parties filed a stipulation of settlement with the Court
through which each party conceded 50 percent of the
understatement amount.3 Petitioners orally moved for an award of
administrative and litigation costs. At the Court's discretion,
petitioners filed a written motion on March 20, 1998.
Discussion
We apply section 7430 as amended by the Taxpayer Relief Act
of 1997 (TRA), Pub. L. 105-34, secs. 1285 and 1453, 111 Stat.
3 In addition, the parties agreed that for 1991 and 1992
there are additions to tax under sec. 6651(a)(1) owed by
petitioners in the amounts of $1,546 and $847, respectively, and
accuracy-related penalties under sec. 6662(a) owed by petitioners
in the amounts of $1,237 and $677, respectively.
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