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officer offered to settle petitioner's case, agreeing to allow
$15,832 of the $19,414 in disallowed itemized deductions and
conceding the accuracy-related penalty in full. The only
adjustments to the return not compromised under the offer of
settlement were disallowance of the deduction for two dependency
exemptions and denial of petitioner's claimed head of household
filing status.
Respondent's offer was not accepted, the case was referred
to District Counsel for trial on November 21, 1996, and a
"Branerton"2 conference was held on December 12, 1996.
On December 18, 1996, near close of business at 4:52 p.m.,
petitioner's representative faxed a document entitled "Dependency
Support Worksheet" to respondent that contained more detailed and
some different information than had previously been provided. On
December 19, 1996, after close of business, at 5:57 p.m.
petitioner's representative faxed to respondent a copy of a
"grant deed" recorded June 29, 1990, conveying title to the
family home from Jeanette Mills to Jeanette Mills and petitioner
as joint tenants.
The parties agreed to settle the case for no deficiency and
no overpayment the very next day, December 20, 1996.
2 See Branerton Corp. v. Commissioner, 61 T.C. 691 (1974)
(requires informal discovery, including discussion, deliberation,
and an interchange of ideas, thoughts, and opinions between the
parties).
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