Maureen Monsour - Page 25

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          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.                         





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