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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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