- 3 -
March 1989, and the Court issued its opinion on July 7, 1992.3
Most of the issues in the cases were resolved adversely to the
Doyles. The deficiencies ultimately determined and assessed were
as follows:
Year Deficiency
1980 $31,854.92
1981 35,007.80
1982 25,209.22
1983 4,600.80
Additionally, respondent assessed more than $294,000 of interest
on the deficiencies.
In 1996, the Doyles filed another petition with this Court,
docket No. 17325-96, seeking redetermination of an additional
deficiency asserted by respondent on their 1983 return. The sole
issue in that case was whether the statute of limitations barred
the additional assessment. The parties stipulated to be bound by
the result in a related case, docket No. 8309-96, in which the
Court held that the period of limitations was still open. See
Doyle v. Commissioner, T.C. Memo. 1997-396, affd. without
published opinion 202 F.3d 253 (3d Cir. 1999). Accordingly, on
January 28, 1998, the Court entered a stipulated decision.4 On
3See Brown v. Commissioner, T.C. Memo. 1992-379, affd.
without published opinion sub nom. Konenkamp v. Commissioner, 14
F.3d 47 (3d Cir. 1993).
4This decision was subsequently affirmed. See Doyle v.
Commissioner, T.C. Memo. 1997-396, affd. without published
opinion 202 F.3d 253 (3d Cir. 1999).
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