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determine any deficiencies based on adjustments to partnership
items. Petitioner filed a petition in which he contended, among
other things, that he had incurred a loss from Arcanum, which
would offset the deficiencies determined.
The parties filed a stipulation of settled issues about
1 year before trial. In it, the parties stipulated that
petitioner is liable for the following:
1. Subject to the provisions of paragraph 4,
below, there are deficiencies in income tax due from
petitioner in the amounts of $31,804.00, [$]71,964.00,
and [$]9,747 for the taxable years 1991, 1992, and
1993, respectively. It is further stipulated that
respondent claims an increased deficiency in income tax
for the taxable year 1991 in the amount of $30,300.00,
pursuant to the provisions of I.R.C. � 6214(a).
2. Subject to the provisions of paragraph 4,
below, petitioner is liable for delinquency penalties
under I.R.C. � 6651(a)(1) in the amounts of $7,771.00,
$17,991.00, and $2,436.75 for taxable years 1991, 1992,
and 1993, respectively. It is further stipulated that
respondent claims an increased delinquency penalty for
the taxable year 1991 in the amount of $7,395.00,
pursuant to the provisions of I.R.C. � 6214(a).
3. Subject to the provisions of paragraph 4,
below, petitioner is liable for estimated tax penalties
under I.R.C. � 6654 in the amounts of $1,776.47,
$3,138.77, and $408.38 for taxable years 1991, 1992,
and 1993, respectively. It is further stipulated that
respondent claims an increased estimated tax penalty
for the taxable year 1991 in the amount of $1,776.47,
pursuant to the provisions of I.R.C. � 6214(a).
4. This stipulation resolves all issues in the
case with the exception of the issues raised by
petitioner in his petition, to wit, whether petitioner
has incurred a loss from Arcanum One Partners, a New
York limited partnership, in any year at issue, which
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