Phillip A. O'Bryon and Cyndie W. O'Bryon - Page 4

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          for the deficiency attributable to Phillip's omitted income, and            
          that both petitioners were liable for the accuracy-related                  
          penalty for the balance of the deficiency, as well as delinquency           
               On September 22, 1998, petitioners timely filed a petition.            
          In addition to asserting that respondent erred in the                       
          determinations set forth in the notice of deficiency, petitioners           
          claimed that Cyndie was entitled to relief under section 6015               
          with respect to deficiencies (including interest, penalties, and            
          other amounts) attributable to understatements of income by                 
               Respondent filed the answer on November 20, 1998, denying              
          any error in the notice of deficiency and denying that Cyndie is            
          entitled to relief under section 6015.  Petitioners filed their             
          reply on January 7, 1999.                                                   
               On December 1, 1998, respondent transferred the case to                
          respondent's Appeals Office.  Shortly thereafter, Appeals officer           
          Allan Fried was assigned the case.                                          
               On February 1, 1999, with the trial scheduled on April 26,             
          1999, the parties filed a joint motion requesting a continuance.            
          We granted the joint motion on February 12, 1999.  After several            
          meetings and communications, the parties reached a full                     
          settlement without trial, and the settlement was executed by the            
          parties on March 20, 2000.  Pursuant to the agreement, Phillip              

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