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Rules 230 through 233.1 Respondent filed responses to both
motions. Neither party requested a hearing. Rule 232(a).
Accordingly, we rule on petitioners' motions on the basis of
the parties' submissions and the record in this case. The
underlying issues raised in the petition were settled, and the
Court entered a stipulated decision.
Upon petitioners' subsequent filing of the motions, the
decision was vacated and set aside. The order decreed that the
stipulated decision document was to be filed as a Settlement
Stipulation.
Respondent determined deficiencies in petitioners' Federal
income taxes for the taxable years 1991, 1992, and 1993 in the
amounts of $102,781, $6,262, and $1,323, respectively. John C.
and Karol Bowden resided in El Paso, Texas, at the time their
petition was filed.
Background
John Bowden, Inc. (the corporation), was incorporated by
John Bowden (petitioner) in June 1991 to perform services in the
insurance industry. Prior to its incorporation, petitioner
operated his business as a sole proprietorship, working under
contract as a district manager for a group of insurance
1All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references, unless otherwise noted,
are to the Internal Revenue Code.
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