Robert and Linda Yuen - Page 3

                                        - 3 -                                         

               On May 9, 1994, Robert and Linda Yuen (petitioners) filed a            
          petition for redetermination with the Court (assigned docket No.            
          7495-94S) contesting a notice of deficiency that respondent had             
          issued to petitioners for 1990.  On March 15, 1995, the Court               
          entered a stipulated decision in docket No. 7495-94S, which                 
          stated that petitioners are liable for a deficiency in income tax           
          for 1990 in the amount of $6,821 and that petitioners are not               
          liable for the accuracy-related penalty under section 6662.  The            
          stipulated decision further stated that petitioners agreed to               
          waive the restrictions that normally would prohibit the                     
          assessment and collection of the deficiency and statutory                   
          interest until the decision of the Tax Court was final.                     
               On or about September 19, 1995, petitioners filed with                 
          respondent a Form 843, Claim for Refund and Request for                     
          Abatement, requesting that respondent abate interest for the                
          taxable year 1990 in the amount of $2,453.69.  Petitioners                  
          asserted in their request that the "IRS had conceded its errors             
          during 1-18-95 meeting" and that petitioners' liability for                 
          interest for 1990 had been compromised as part of the                       
          negotiations leading to the entry of the stipulated decision in             
          docket No. 7495-94S.  Petitioners further asserted that                     
          respondent had acknowledged that the stipulated decision in                 
          docket No. 7495-94S represented a compromise of petitioners'                

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011