Robert T. Brewer - Page 2

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          filed a response to petitioner’s motion to vacate.  Because                 
          petitioner has not shown that the circumstances of the settlement           
          warrant our vacating the decision, we shall deny petitioner’s               
          motion to vacate.                                                           
               On April 1, 2002, respondent issued a notice of deficiency             
          to petitioner determining a deficiency of $58,812 in petitioner’s           
          1999 Federal income tax.  The notice of deficiency also                     
          determined additions to tax for 1999 under sections 6651(a)(1)              
          and (2) and 6654(a) of $12,382.65, $4,677.89, and $2,622.75,                
          respectively.  Respondent issued the notice of deficiency as a              
          result of petitioner’s failure to timely file his 1999 Federal              
          income tax return.  On June 24, 2002, petitioner timely filed a             
          petition challenging respondent’s determination.  In November               
          2002, petitioner filed his 1999 return.  As a result, petitioner            
          and respondent were thereafter able to resolve many of the issues           
          raised in the notice of deficiency.                                         
               This case was calendared for the Court’s trial session in              
          Mobile, Alabama, beginning on September 7, 2004.  On the morning            
          of the Court’s calendar call, petitioner and counsel for                    
          respondent, Mr. Friday, met and executed a stipulated decision.             
          Petitioner and Mr. Friday then appeared before the Court and                
          informed the Court that a settlement had been reached.  The                 
          stipulated decision was submitted to the Court on September 7,              

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