John G. Goettee, Jr. and Marian Goettee - Page 11

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              Petitioners contend that, under section 6601(c), interest               
         should have stopped accruing on January 13, 1995, 30 days after              
         they transmitted to Rowland the executed decision document, which            
         included a waiver of restrictions on assessment pursuant to                  
         section 6213(d).  They argue that “any suggestion that Respondent            
         has the right to decide when to file stipulated decision                     
         documents” is a “tortured interpretation” of section 6601(c).                
              Respondent maintains that all of respondent’s interest                  
         computations comport with section 6601(c), and that interest                 
         properly stopped accruing on June 1, 1995, 30 days after the                 
         decision document was entered by the Court.                                  
              The language of the parties’ agreed-upon waiver itself                  
         resolves this issue.  See also, e.g., Pallottini v. Commissioner,            
         90 T.C. 498, 502-503 (1988), where we focused on the text of the             
         document (in that case, a statute) itself, rather than general               
         rules, in order to determine the document’s effect.                          
              The parties stipulated as follows:                                      
              effective upon entry of this decision by the Court, the                 
              petitioners waive the restriction contained in I.R.C.                   
              6213(a) prohibiting assessment and collection of the                    
              deficiencies in income tax and additions to tax (plus                   
              statutory interest) until the decision of the Tax Court has             
              become final.                                                           

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