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received from the Bureau of Labor Statistics. On October 27,
1994, and on December 14, 1994, petitioner and Ms. Craig filed
joint 1990 and 1991 Federal income tax returns, respectively.
Those returns were treated by respondent as amended returns. On
February 3, 1995, petitioner and Ms. Craig filed a joint 1992
Federal income tax return.
On October 5, 1995, respondent issued a notice of deficiency
to petitioner and Ms. Craig. The notice determined that
petitioner and Ms. Craig were liable for deficiencies in their
1990, 1991, and 1992 Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $6,700 $1,675 $441
1991 50,686 12,672 2,913
1992 6,814 1,704 294
Petitioner and Ms. Craig petitioned the Court with respect
to the notice on December 21, 1995. On February 24, 1997,
petitioner and Ms. Craig signed a stipulated decision. This
decision listed the deficiencies in Federal income tax due from
petitioner and Ms. Craig in accordance with the notice of
deficiency and provided that “effective upon the entry of the
decision by the Court, petitioners [petitioner and Ms. Craig]
waive the restriction contained in Internal Revenue Code �
6213(a) prohibiting assessment and collection of the deficiencies
and additions to the tax (plus statutory interest) until the
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