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Background
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
1(...continued)
monetary amounts have been rounded to the nearest dollar.
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Last modified: May 25, 2011