Michael Craig v. Commissioner - Page 4




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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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