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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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Last modified: May 25, 2011