John Bowden, Inc. - Page 2

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          through 233.  Neither party requested a hearing.  Rule 232(a).              
          Accordingly, we rule on petitioner's motion for litigation costs            
          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 petitioner's             
          subsequent filing of the motion, the decision was vacated and set           
          aside by order.  It was decreed in this order that the stipulated           
          decision document was to be filed as the Second Settlement                  
               For taxable years ending June 30, 1992 and 1993, respondent            
          determined deficiencies in John Bowden, Inc.'s Federal income               
          taxes in the amounts of $8,539, and $5,195, respectively.  John             
          Bowden, Inc., was a Texas corporation with a principal place of             
          business in El Paso, Texas, at the time the petition was filed.             
               John Bowden, Inc. (petitioner or corporation) was                      
          incorporated by John Bowden in June 1991 to perform services in             
          the insurance industry.  Prior to its incorporation, Mr. Bowden             
          operated the business as a sole proprietorship, working under               
          contract as a district manager for a group of insurance                     

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