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claimed on Schedule E of petitioners’ jointly filed Federal
income tax returns for 1986 through 1991.
Frank Lamanna and Lidia Lamanna each filed a petition with
this Court. At the time the petitions were filed petitioners
resided in Los Angeles, California. Respondent filed an answer
to each petition and later filed a motion to consolidate for
trial, briefing, and opinion. On January 20, 2000, we granted
respondent’s motion to consolidate.
These consolidated cases were originally set for trial on
January 24, 2000. Petitioners moved for a continuance on four
separate occasions, based on a variety of grounds, including but
not limited to an opportunity for petitioners to engage counsel.
These cases were set for trial at the trial session
beginning May 13, 2002. The parties executed on May 13, 2002, a
stipulation of settled issues that covered all taxable years in
issue.2 The stipulation, filed on May 14, 2002, set forth
numerous adjustments that resulted in no deficiencies, no
additions to tax, and no penalties for taxable years 1987 through
1991. For 1986, the remaining taxable year, the stipulation
provided in pertinent part:
2 While there are two docketed cases before the Court,
there is one stipulation of settled issues which addresses all
issues in each of these consolidated cases.
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