Lidia Lamanna - Page 5

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          respondent’s decision proposed the following deficiency and                 
          additions to tax:                                                           
                                           Sec.         Sec.                          
            Year Deficiency Sec. 6651(a)6653(a)(1)(A)6653(a)(1)(B) Sec. 6654           
            1986   $3,096      $774       $154.80      $3,096     $149.78             
               Respondent sent each petitioner a letter dated July 5, 2002,           
          enclosing the proposed decision document with supporting                    
          computations.  Petitioners refused to sign the decision document            
          for a variety of reasons.  First, petitioners claim that the                
          decision document does not conform with the terms of the                    
          stipulation of settled issues.  Second, they claim that they were           
          denied an opportunity to consult with an attorney prior to                  
          signing the stipulation of settled issues.  Third, they claim               
          that respondent’s counsel misled them into believing the                    
          stipulation they signed was not final and could be subject to               
          revisions.                                                                  
               In particular, petitioners wanted to revise the signed                 
          stipulation, with respect to the 1986 taxable year, to show a               
          Schedule A mortgage interest deduction of $29,305 instead of the            
          listed amount of $5,218 and to include Schedule E rental income             
          of only $127,752 instead of the $172,752 amount listed on their             
          1986 Federal income tax return.  Petitioners were aware that the            
          Schedule A mortgage interest deductions were in issue prior to              
          their signing the stipulation of settled issues.  Petitioners               
          claim that respondent’s counsel agreed to allow further interest            





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