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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.
Background
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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