- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011