Robert L. and Joanne Tammaro - Page 8




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               By notice dated August 12, 1998, the Court calendered                  
          petitioner’s case for trial on November 2, 1998.  Early in                  
          October 1998, petitioner and respondent entered into settlement             
          negotiations.  At the November 2, 1998, calendar, counsel for               
          respondent advised the Court that a basis for settlement had been           
          reached by the parties and requested 90 additional days to submit           
          the decision document.  On December 24, 1998, respondent filed a            
          motion to restore the case to the general trial calendar,                   
          reporting that a disagreement had arisen between the parties                
          regarding the tax computations for the income tax and net                   
          operating losses.                                                           
               Petitioner’s case was restored to the general calendar.  By            
          Notice dated June 15, 1999, this case was calendared for trial at           
          the Court's trial session on September 7, 1999.  The parties                
          resumed settlement negotiations.  Counsel for respondent                    
          determined that the hazards of litigation, as well as the cost of           
          trying the case, warranted a concession by respondent of a small            
          percentage of the losses attributable to the horse activity that            
          had been disallowed in the notice of deficiency for 1993 and 1994           
          and that had been disallowed for 1991 and 1992.  Respondent also            
          determined that the hazards of litigation did not warrant any               
          concession by respondent of the loss attributable to the horse              
          activity that had been disallowed for 1990.  Respondent’s                   
          concession with respect to the small portion of the losses                  






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