- 2 -
ers’ motion.
Background
On October 29, 1997, respondent issued a notice of defi-
ciency (notice) to petitioners that determined the following
deficiencies in, and fraud penalties under section 6663(a)1 on,
petitioners’ Federal income tax (tax):
Fraud Penalty
Year Deficiency Under Sec. 6663(a)
1991 $18,508 $13,881
1992 40,931 30,698
1993 70,662 52,997
On December 29, 1997, petitioners timely filed pro sese a
petition. This case was calendared for trial at the Court’s
trial session in Los Angeles, California, that commenced on
February 8, 1999.
On February 2, 1999, Robert H. Appert (Mr. Appert) entered
an appearance on behalf of petitioners. On February 8, 1999, the
parties filed a stipulation of settled issues, a first supplemen-
tal stipulation of settled issues, and a second supplemental
stipulation of settled issues (collectively, stipulations of
settled issues). Each of those stipulations was signed on
February 6, 1999, by Mr. Appert on behalf of petitioners as well
as by each petitioner and by Mr. Jojola on behalf of respondent.
On March 11, 1999, the parties submitted to the Court a stipu-
1All section references are to the Internal Revenue Code in
effect at relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011