Nina H. Pettyjohn - Page 6




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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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