Agapito Fajardo and Clara S. Fajardo - Page 2

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               In his notice of deficiency dated March 5, 1997, respondent            
          determined the following deficiencies in income tax and an                  
          addition to tax:                                                            
                                                       Addition to tax                
               Year                Deficiency          sec. 6651(a)(1)                
               1991                $50,118                 1$14,107                   
               1993                23,700                     ---                     
               1The first page of the notice of deficiency shows an                   
          addition to tax under sec. 6651(a)(1) with respect to 1993, not             
          1991.  However, our review of the notice in its entirety reveals            
          that the determination regarding the addition to tax was made               
          with respect to 1991.  In his motion for summary judgment,                  
          respondent confirmed that a typographical error was made in the             
          notice, and that the addition to tax was determined with respect            
          to 1991.                                                                    
               Petitioners filed a timely petition and designated Los                 
          Angeles, California, as the place of trial.  Petitioners resided            
          in Carson, California, on the date their petition was filed.                
          References to petitioner are to Agapito Fajardo.                            
               On November 26, 1997, respondent's counsel sent petitioners            
          a Branerton letter, see Branerton Corp. v. Commissioner, 61 T.C.            
          691 (1974), advising them of the Court's policies and                       
          requirements regarding informal exchange of documentation and               
          stipulation of facts and inviting petitioners to attend a                   
          conference for that purpose on December 19, 1997.  Petitioners              

          monetary amounts have been rounded to the nearest dollar.                   

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