John A. Rowe and Donna L. Rowe - Page 66




                                       - 66 -                                         
                                      Appendix                                        
               In stipulations of agreed issues, petitioner John A. Rowe              
          conceded the following deficiencies in income taxes, additions to           
          tax, and penalties:38                                                       
                          Additions to Tax and Penalties                              
          Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B)   Sec. 6661           
          1987  $173,817      $130,363                 1         $43,454              
                              Sec. 6653(b)(1)           Sec. 6661                     
          1988  $ 53,937           $40,453             $13,484                        
                               Sec. 6651(a)(1)          Sec. 6663                     
          1989  $ 73,279           $13,792             $54,959                        
                              Sec. 6654                Sec. 6662(c)                   
          1990  $124,891           $8,057              $24,978                        
               150 percent of the interest due on $173,817.                           
               In a stipulation of settled issues, respondent and                     
          petitioner Donna L. Rowe agreed to the following disposition of             
          certain issues:                                                             
               Ms. Rowe conceded that she is not entitled to relief from              
          joint liability for an $85 theft loss adjustment in 1987 and a              
          $6,253 income adjustment in 1990.  Ms. Rowe also conceded that              
          she is not entitled to relief from joint liability for $48.50 of            
          interest income, still in dispute, which was part of a $4,847               
          adjustment in 1990.                                                         
               Respondent conceded that Ms. Rowe is entitled to relief from           
          joint liability under section 6015(c) for a $6,282 rental income            


               38Petitioner John A. Rowe’s concessions encompass all the              
          determinations made by respondent in the notices of deficiency.             





Page:  Previous  48  49  50  51  52  53  54  55  56  57  58  59  60  61  62  63  64  65  66  67  Next

Last modified: May 25, 2011