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of deficiency for those years in March 1993. Petitioner filed a
petition in this Court disputing the deficiencies for 1988 and
1990. In March 1994 petitioner and respondent entered into a
settlement agreement. The Court entered a stipulated decision on
March 29, 1994, that there were deficiencies in petitioner's
Federal income taxes in the amounts of $637 for 1988 and $982 for
1990, that there was an addition to tax due for 1988 under
section 6653(a)(1) in the amount of $31, and that there was a
penalty due for 1990 under section 6662(a) in the amount of $196.
The parties’ stipulation, included as part of the decision,
stated that “the above noted deficiencies do not take into
account social security taxes (FICA) or the FICA tax penalty”,
and that petitioner waived the restriction under section 6213(a)
on the assessment and collection of “the deficiencies and the
additions to tax (plus statutory interest) and the penalty until
the decision of the Tax Court has become final”.
Respondent assessed the deficiency in income tax and the
addition to tax for 1988 on July 11, 1994. Respondent assessed
the deficiency in income tax and the penalty for 1990 on May 30,
1994. Consistent with the parties’ stipulation and the decision
of the Court that reduced the determined deficiencies, respondent
appropriately abated portions of the FICA tax, the FICA
penalties, and interest. Further, pursuant to section 6601(c),
respondent suspended the accrual of interest on the deficiencies
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