Elliot G. Steinberg - Page 6




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          respect to the deficiencies, additions to tax, and increased                
          interest but contained a paragraph that $67,078 had been paid on            
          December 21, 1988, on the deficiency for 1980, which amount was             
          not reflected in the agreed deficiency for 1980.                            
               Respondent informed petitioner by letter dated February 22,            
          1998, that respondent did not agree with the added stipulation              
          and would not sign the decision document prepared by petitioner.            
          On October 9, 1998, petitioner filed a motion characterized as a            
          "Motion to Compel Computation for Entry of Decision Pursuant to             
          Rule 155."  By Order dated October 15, 1998, the Court filed                
          petitioner's motion as a "Motion to Compel Computation for Entry            
          of Decision" because no opinion had been issued in this case.               
          Respondent was ordered to file with the Court a written response            
          to petitioner's motion.                                                     
               Respondent filed a response to petitioner's motion.  Based             
          upon this response, which recited the above facts, the Court                
          denied petitioner's motion to compel computation for entry of               
          decision.  Further, the Court ordered petitioner to show cause              
          why a decision should not be entered in this case in accordance             
          with the decision document prepared by respondent, since there is           
          no dispute with respect to the deficiencies in tax, additions to            
          tax, and increased interest for the 1980 and 1981 tax years.                
               In his response to the show cause order, petitioner requests           
          that the Court enter a decision in the form he prepared or,                 





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