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$309,923 and $326,767 in 1994 and 1995, respectively, for
management consulting fees paid to Lauzon, Jr. The $104,000
payments were also recorded on petitioners books as management
consultant fees paid to Lauzon, Jr.; however, petitioner later
reclassified these payments as expenses incurred in scouting new
talent. Considering the amount of the management consultant fees
paid to Lauzon, Jr., the Appeals officer believed that the
$104,000 payments may have been excessive compensation.
Accordingly, on September 10, 1999, the Appeals officer
initiated a discussion with petitioner's accountant to resolve
this last item. On September 16, the Appeals officer and
petitioner agreed to split the $104,000--one-half of the amount
claimed was allowed as a deduction in each year, and one-half was
disallowed.
On September 24, 1999, the Appeals officer received the
audit department's computation and prepared the stipulated
decision document. The decision document showed income tax
deficiencies of $8,354 and $8,000 for 1994 and 1995,
respectively. On October 30, 1999, Mr. Patten signed the
stipulated decision document and respondent signed it two days
later. The Court entered the stipulated decision on November 5,
1999.
Petitioner thereafter filed a motion to vacate the decision
and a motion for administrative and litigation costs. Petitioner
claims that it incurred $61,632 in administrative and litigation
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