Chih H. and Chu F. Chu - Page 2




                                        - 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.                                      





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