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On April 24, 2002, respondent and petitioner entered into a
stipulation relating to the partner-level proceeding, which
included the following language:
4. The tax treatment of petitioner’s partnership
items relating to WIN Enterprise, LC and Stephens City
Chiropractic, PLC will be resolved in a separate
partnership proceeding conducted in accordance with the
TEFRA partnership procedures.
5. The adjustments necessary to apply the results
of the TEFRA partnership proceeding described in
subparagraph 4 to petitioner, shall be treated as
computational adjustments under I.R.C. � 6231(a)(6) and
assessed, credited or refunded accordingly.
6. To the extent that the computation of
petitioner’s tax liability which properly reflects the
tax treatment of the partnership items relating to WIN
Enterprise, LC and Stephens City Chiropractic, PLC, as
determined in the TEFRA partnership proceeding
described in subparagraph 4, would also result in a
change in petitioner’s tax liability attributable to
nonpartnership items, as previously determined in this
docketed proceeding, such change may be treated as a
computational adjustment under I.R.C. � 6231(a)(6) and
assessed, credited or refunded accordingly.
The stipulation further provided that petitioner was entitled to
overpayments of $716 and $709 relating to 1996 and 1997,
respectively,4 and that petitioner owed no section 6662(a)
accuracy-related penalties relating to those years.
On April 26, 2002, this Court entered a decision that
incorporated the facts stipulated by the parties as the findings
of the Court.
4 The overpayments resulted from interest expense
deductions relating to payments petitioner made on behalf of SCC
in 1996 and 1997.
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Last modified: May 25, 2011