Chih H. and Chu F. Chu - Page 3




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          lated decision document (stipulated decision document) that was             
          signed on March 10, 1999, by Mr. Appert on behalf of petitioners            
          and by a representative of respondent and that reflected the                
          agreement of the parties as set forth in the stipulations of                
          settled issues.                                                             
               On March 15, 1999, the Court entered a decision in this case           
          pursuant to the agreement of the parties as reflected in the                
          stipulated decision document2 that petitioners are not liable for           
          the fraud penalty under section 6663(a) for any of the years at             
          issue and that they are liable for deficiencies in, and accuracy-           
          related penalties under section 6662(a) on, petitioners’ tax, as            
          follows:                                                                    
          Fraud Penalty     Accuracy-Related Penalty                                  
          Year       Deficiency     Under Sec. 6663(a)     Under Sec. 6662(a)         
          1991      $2,973              None                   $595                   
          1992          6,008              None                  1,202                
          1993         20,379              None                  4,076                
          Discussion                                                                  
               The Court’s decision in this case was entered pursuant to              
          the agreement of the parties on March 15, 1999.  No notice of               
          appeal or timely motion to vacate or revise the decision was                
          filed in this case, see sec. 7483 and Rule 162, and the decision            
          herein became final on June 13, 1999, see sec. 7481(a)(1); Fed.             
          R. App. P. 13(a).                                                           

               2On Mar. 26, 1999, after the decision in this case was                 
          entered, Mr. Appert filed a motion to withdraw as attorney of               
          record for petitioners in this case.  On Apr. 22, 1999, the Court           
          granted Mr. Appert’s motion.                                                





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