- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011