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Initially, petitioner refused to execute the proposed
stipulated decision, even though she accepted the $2,115
deficiency, because “The IRS tax-examiners are at fault.”
Since the IRS tax-examiners are responsible for
allowing the gift-giving for a total of eight years
[petitioner wrote], compound interest should be waived
* * * . A deficiency occurred because of complete and
total failure of their job performance. They were
responsible, through their determination, for eight
years of erroneous refund checks.
Ultimately, however, on October 14, 1997, petitioner executed the
proposed stipulated decision, which was entered by the Court on
November 17, 1997. See sec. 7459(a), (c).
The stipulated decision included a number of stipulations by
the parties, among them the following:
It is further stipulated that there is a
prepayment credit for the taxable year 1993 in the
amount of $1,500. It is stipulated that the deficiency
for the taxable year 1993 is computed without
considering the prepayment credit of $1,500.
* * * * * * *
It is further stipulated that interest will be
assessed as provided by law on the deficiency in tax
due from petitioner.
On February 9, 1998, respondent assessed the $2,115
deficiency in income tax, together with interest of $602.67. On
that same date, respondent also sent petitioner a notice of
balance due.
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