- 6 -
1992 1993 1994
Deficiencies $18,647 $2,164 -0-
Penalties 3,729 -0- -0-
Additions to tax -0- -0- -0-
Total 22,376 2,164 -0-
Petitioners rejected this settlement offer.
Counsel for both parties, along with respondent’s Appeals
officer, met on March 23, 1999. Counsel again met on April 2,
1999, this time with petitioner present. Respondent and
petitioners dispute whether and to what extent new evidence was
given in these later stages of negotiation to substantiate the
amounts claimed as cost of goods sold. The parties also dispute
whether petitioners’ personal conversations with respondent’s
counsel yielded information previously not available to
respondent. After this meeting, however, respondent made the
decision to concede the case in whole to petitioners.
A stipulated decision was entered on May 11, 1999. The
decision document stated that petitioners were not liable for any
deficiencies, penalties, or additions to tax.1 The Statement of
Income Tax Changes–-prepared by respondent and filed with the
1 The Statement of Income Tax Changes lists an
overassessment for taxable year 1992 in the amount of $1,376.
The decision document, however, states that there were no
overpayments in the years at issue.
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Last modified: May 25, 2011