Thomas J. Fisher and Ann M. Fisher, et al. - Page 6




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          petitioners had paid for the years 1981 through 1985 -- including           
          the $130,836 that petitioners had paid on December 27, 1988.                
               On May 2, 1995, petitioners and respondent submitted to the            
          Court an agreed and signed decision document in docket No.                  
          11904-88, involving petitioners’ Federal income tax liability for           
          1982, in which petitioners agreed to a tax deficiency for that              
          year of $44,693.                                                            
               On April 26, 1995, one of respondent’s Appeals officers                
          wrote a letter to petitioners to explain the allocation by                  
          respondent of the total $130,836 in payments that had been                  
          received from petitioners on December 27, 1988.  In that letter,            
          a misleading statement was made by respondent’s Appeals officer             
          relating to petitioners’ Federal income tax liabilities that                

               There remains no balance on the 1984 account, but each                 
               of the other years show a balance in your favor which                  
               will be refunded when this matter is closed.                           

               At a Court hearing in petitioners’ case at docket No. 27394-           
          86 in New York City on December 9, 1997, the parties orally                 
          settled issues relating to petitioners’ investment in White Rim             
          for 1980 and 1981, and the parties filed their stipulation of               
          settled issues therein on December 9, 1999.                                 











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