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respondent's counsel March 28, and signed by respondent's counsel
and sent to the Tax Court on April 10, 2000.
Under the settlement agreement between the parties, the
amounts proposed in the Appeals letter of January 11, 2000, for
cost of goods sold and legal and professional fees for 1996 were
accepted. The utilities expense adjustment for 1995 of $547 was
reduced by $700 under the agreement.
The parties have stipulated that petitioners take the
position that respondent was not substantially justified in
making adjustments to petitioners': (a) Deduction of certain
utilities expenses for 1995; (b) deduction of a portion of car
and truck, insurance, office, and utilities expenses for 1995;
(c) claim of a portion of cost of goods sold for 1996; and (d)
deduction of legal and professional fees for 1996.
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