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Background
From 1984 through 1990, petitioner commenced four cases in
this Court for the redetermination of deficiencies in Federal
income taxes and additions to tax for each of the four taxable
years 1980 through 1983. See sec. 6213(a). A description of
each of those four cases follows herein:
A. Taxable Year 1980
On June 15, 1984, respondent issued a notice of deficiency
to petitioner determining a deficiency of $576,896 in his Federal
income tax for 1980. Respondent also determined that petitioner
was liable for an addition to tax under section 6653(a) for
negligence or intentional disregard of rules and regulations.
On October 29, 1984, petitioner filed a petition with the
Court (assigned docket No. 37347-84) contesting the notice of
deficiency for 1980.2 In February 1986, shortly before
petitioner's case was scheduled for trial, petitioner entered
into a stipulated decision with respondent agreeing to a
deficiency in income tax and an addition to tax under section
6653(a) for 1980 in the amounts of $190,291 and $9,515,
respectively. Petitioner subsequently filed a motion to vacate
the stipulated decision. In MacElvain v. Commissioner, T.C.
2 The petition was timely filed within the 150-day period
prescribed by sec. 6213(a).
There is no support in the record for petitioner's assertion
that he did not file a petition for 1980 until May 22, 1986.
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