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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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Last modified: May 25, 2011