- 5 -
Stock Ownership Plan in Docket No. 18155-96 “R” (whether
litigated or settled), with respect to the following
taxpayer:
Name of Case: Howard E. Clendenen, Inc. v. Commissioner
Tax Court Docket No.: 18155-96 “R”
(hereinafter the CONTROLLING CASE).
3. The petitioner in this case is the same as the
taxpayer in the CONTROLLING CASE.
Mr. Clendenen’s stipulation to be bound provided that the
only remaining issues in dispute involve the issues asserted in
paragraph 4(a) of the petition that relate to the plan’s
qualification. Further, Mr. Clendenen’s stipulation to be bound
provided in part:
2. The adjustments in respondent’s notice of
deficiency relating to the issues or items asserted in
paragraph 4(a) of the petition, as specified in the
preamble, shall be determined by the resolution of the
qualified status of the Howard E. Clendenen, Inc., Employee
Stock Ownership Plan in Docket No. 18155-96 “R” (whether
litigated or settled), with respect to the following
taxpayer:
Name of Case: Howard E. Clendenen, Inc. v. Commissioner
Tax Court Docket No.: 18155-96 “R”
(hereinafter the CONTROLLING CASE).
3. All issues involving the above adjustments shall be
resolved as if the petitioner in this case were the same as
the taxpayer in the CONTROLLING CASE.
Both stipulations to be bound also provided:
4. A decision shall be submitted in this case when the
decision in the CONTROLLING CASE (whether litigated or
settled) becomes final under I.R.C. � 7481.
5. Upon entry of the decision in the CONTROLLING CASE,
petitioner consents to the assessment and collection of the
deficiencies attributable to the adjustments formulated by
reference to the Tax Court’s opinion, notwithstanding the
restrictions under I.R.C. � 6213(a).
The parties agree to this STIPULATION TO BE BOUND.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011