Robert T. Brewer - Page 3

                                        - 3 -                                         
          2004, signed by petitioner and Mr. Friday.  On September 13,                
          2004, the Court entered the stipulated decision.                            
               The first page of the decision reflects that there is a                
          deficiency of $4,878 in petitioner’s 1999 Federal income tax and            
          that petitioner is not liable for any additions to tax.  Page 2             
          of the decision states:                                                     
                    It is hereby stipulated that the Court may enter                  
               the foregoing decision in this case.                                   
                    It is further stipulated that interest will be assessed           
               as provided by law on the deficiency due from petitioner.              
                    The above deficiency does not take into account                   
               withholding credits of $3,778.00 made for the taxable year             
               1999 by the petitioner.                                                
                    It is further stipulated that, effective upon the entry           
               of this decision by the Court, petitioner waives the                   
               restrictions contained in I.R.C. � 6213(a) prohibiting                 
               assessment and collection of the deficiency (plus                      
               statutory interest) until the decision of the Tax Court                
               becomes final.                                                         
          The decision bears the signatures of petitioner and Mr. Friday on           
          page 2.                                                                     
               Rule 162 allows a party to file a motion to vacate or revise           
          a decision within 30 days after the decision has been entered,              
          unless the Court “shall otherwise permit” that 30-day period to             
          be extended, but Rule 162 does not provide a standard by which              
          this Court should evaluate a motion to vacate a decision.  Rule             

Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011