Michael A. Lacher and Judith W. Lacher - Page 9




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          petitioners now contend that they should be relieved of the                   
          additions to tax for negligence because respondent has a duty to              
          afford substantially equal treatment to similarly situated                    
          taxpayers.  Petitioners further contend that respondent breached              
          his duty when he failed to offer them the so-called standard                  
          settlement offer that was made available to other taxpayers.                  
          Petitioner asserts that he was first made aware of the standard               
          settlement offer sometime during middle or late 1999 and that he              
          would have accepted the standard settlement offer if he had                   
          received it.  At trial, petitioner failed to present evidence                 
          that demonstrates that he or his counsel attempted to settle the              
          case.  Instead, petitioner conceded that he never attempted to                
          settle with respondent.                                                       
               On March 8, 2000, the parties filed an amended Stipulation               
          of Settled Issues.  In this stipulation, petitioners concede that             
          they are liable for the addition to tax under section 6659 for                
          1981.  Petitioners also concede that section 6501 does not bar                
          the assessments for 1978 and 1979.  At trial, petitioners also                
          conceded that their only challenge to the additions to tax for                
          negligence under section 6653 is their present argument that they             
          were denied equal treatment.                                                  
          Consents To Extend Period of Limitations                                      
               On their 1981 Federal income tax return, petitioners listed              
          their address as “C/O Stuart Becker & Co. 665 Fifth Ave., New                 






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