- 3 - Rule 91(a) requires the parties to stipulate all evidence that fairly should not be in dispute. Petitioner refused to execute a written stipulation prepared by respondent that would have placed into evidence copies of petitioner's Federal income tax returns for the years at issue and copies of the notices of deficiency for those years. These documents were admitted into evidence over petitioner's objection. At the time the petitions were filed, petitioner's legal residence was Las Vegas, Nevada. Petitioner is a retired attorney. He was not engaged in the practice of law during the years at issue. On his 1995 and 1996 Federal income tax returns, he reported wage and salary income as well as income from a trade or business activity described as insurance sales. The wage and salary income reported on the 1995 return came from two family and medical health plans for which the employers issued Internal Revenue Service (IRS) Forms W-2, Wage and Tax Statement. The wage and salary income reported on the 1996 return was from an employer named IMC Trading, Inc., also based on an IRS Form W-2. 3(...continued) deficiencies at issue in this case cannot be assessed until the Court issues a decision. A "no change" letter issued by respondent does not generally preclude respondent from subsequently issuing a notice of deficiency. Opine Timber Co. v. Commissioner, 64 T.C. 700, 712 (1975), affd. without published opinion 552 F.2d 368 (5th Cir. 1977).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011