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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
Stipulation.
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.
Background
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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