- 25 - case. That was because the issues were factually intensive and required Mr. Laubach to ask Mr. Winschel to provide him with certain documents that Mr. Winschel claimed supported the posi- tions of petitioner and Mr. Monsour with respect to the case for the taxable years at issue. Based upon certain documentation that Mr. Winschel provided to Mr. Laubach, respondent conceded respondent’s determination of omitted income with respect to Georgetown Square for one or more of the taxable years 1989, 1991, 1992, and 1993 not disclosed by the record.14 On October 8, 1998, pursuant to the agreement of the par- ties, the Court entered a decision in the case for the taxable years at issue (stipulated decision in the case for the taxable years at issue). That decision provided as follows: Pursuant to agreement of the parties in this case, it is ORDERED and DECIDED: That there are deficiencies in income tax due from the petitioners for the taxable years 1989, 1991, 1992, and 1993 in the amounts of $31,349, $8,943, $9,773, and $28,578, respectively. That the following statement shows the petition- ers’ income tax liability for the taxable year 1990: 14The record does not establish whether respondent conceded in full and/or compromised in part any of the other determina- tions in the notice for the taxable years at issue.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011