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On January 9, 1996, respondent issued to petitioner a
statutory notice of deficiency for tax year 1993 determining a
deficiency in income tax of $6,166 and a section 6662(a)
accuracy-related penalty of $1,233.
The deficiency resulted from respondent's determination that
petitioner was not entitled to: (a) Itemized deductions for home
mortgage interest and charitable contributions; (b) deductions
for dependency exemptions; and (c) head of household filing
status. Respondent determined that petitioner was liable for the
section 6662 accuracy-related penalty because part of the
underpayment of tax for the year was due to negligence.
Petitioner, then a resident of Menlo Park, California,
timely filed his petition on April 12, 1996, and it was followed
by respondent's answer, filed timely on June 3, 1996. On
October 22, 1996, the Court issued a notice setting the case for
trial on January 6, 1997, at San Francisco, California. The
case, however, was settled before trial, and a stipulation of
settlement was filed February 26, 1997. The stipulation of
settlement reflects that no deficiency or overpayment is due and
that there is no liability for the accuracy-related penalty under
section 6662.
Petitioner filed a motion for the award of litigation and
administrative costs, in response to which respondent filed a
notice of objection. Neither party requested a hearing in this
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