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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
penalties.
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
Phillip.
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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