- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011