- 5 - 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, whichPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011