- 2 - documents and shares them with respondent. We hold that we shall not. Section references are to the Internal Revenue Code for the year in issue. Background Respondent determined a $59,114 deficiency in petitioner's 1995 Federal income tax and additions thereto of $2,662.95 and $3,205.33 under sections 6651(a)(1) and 6654, respectively. While residing in Illinois petitioner petitioned the Court to redetermine these amounts. The Court set this case for trial in Chicago, Illinois, on March 20, 2000. On the date set for trial the parties filed the stipulation, and the Court ordered that the stipulated decision document be submitted to the Court by April 19, 2000. Petitioner now refuses to sign the decision document, asserting that he has recently become aware that documents may exist which support the allegations set out in his petition. Petitioner asserts: petitioner believes that the financial records and information [alleged to be newly discovered but not in petitioner’s possession] will indicate that the taxable income amounts, related tax liability, and interest and penalty previously conceded in the stipulation of settled issues, are inaccurate and petitioner is harmed by conceding to such amounts. Petitioner does not move the Court to vacate the stipulation1 but 1Even assuming arguendo, that petitioner is making such a motion through his response to respondent's motion for entry of decision, we would deny the motion under the rationale of Stamm Intl. Corp. v. Commissioner, 90 T.C. 315, 321 (1988)Page: Previous 1 2 3 4 Next
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