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adjustment in 1990 and for $112,979 of the $116,405 lump-sum
distributions adjustment in 1990.
In the stipulation of facts and first supplemental
stipulation of facts, the following concessions were made:
Respondent conceded that, pursuant to section 6015(c), Ms.
Rowe is not liable for any deficiency associated with unreported
income of $283,928, $29,924, $94,648, and $82,053, respectively
for the years 1987 through 1990. Respondent conceded that Ms.
Rowe is entitled to relief from joint liability under section
6015(c) for 1990 with respect to the following adjustments: (1)
Capital gain income of $11,919; (2) Schedule C income of $82,053;
and (3) all but $48.50 of interest income which was part of a
$4,847 adjustment.
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