- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011