- 5 - 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 interestPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011