Michael R. and Sheila Olsen - Page 2




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          stipulation of facts and several hours of testimony by petitioner           
          Sheila Olsen, the Court called a recess.  The parties then met to           
          confer and negotiate in private.  When the Court recalled the               
          case, counsel for respondent announced that the parties had                 
          reached a settlement.  Respondent's counsel read the oral                   
          stipulation of settlement into the record as follows:                       
               Following along the notice of deficiency, there was                    
               unemployment compensation of $423, which the                           
               petitioners agree belongs in their income.  * * * There                
               were Schedule C other expenses of $4,071.  The                         
               petitioners agree they're not allowed those expenses.                  
               There was a depreciation Schedule C expense allowed of                 
               $881 to the taxpayer's credit.  Petitioners agree they                 
               will not take that additional depreciation.  And the                   
               petitioners agree that they are not entitled to $5,280                 
               of rent that was previously allowed.  This will result                 
               in an increased deficiency.                                            
               Respondent's counsel further noted that there was no penalty           
          in the notice of deficiency, and under the stipulated settlement            
          there still are no penalties.  The Court then asked petitioners             
          whether the oral stipulation, as read into the record by                    
          respondent's counsel, was satisfactory.  Petitioners each                   
          replied, "Yes, your Honor."                                                 
               The Court then ordered the parties to submit a written                 
          stipulation for decision within 30 days.  The Court further                 
          stated that the Court would entertain a motion for entry of                 
          decision if the Court did not receive a stipulation for decision.           
          The Court again inquired whether petitioners understood the                 
          Court's insistence on a stipulation for decision and its                    






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