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were sent to petitioners. On December 26, 2001, Jacob sent a
letter to each petitioner which referenced his case and stated
that Jacob had received “the last of the requisite documents from
the Internal Revenue Service wrapping up the nine-year mess
related to * * * [your] sale of Pennysaver.” Petitioners each
received a copy of this letter, and both understood from this
letter that the cases pending before this Court were being
resolved.
On January 28, 2002, Jacob sent a letter to respondent,
enclosing executed decision documents for both cases; copies of
this letter and the decision documents were sent to petitioners
and to Hesselbacher. On February 7, 2002, the Court ordered the
parties to file status reports on or before February 21, 2002.
Jacob sent a letter dated February 8, 2002, in response to the
order in which he advised the Court that he had signed decision
documents and returned them to respondent; copies of this letter
were sent to petitioners.
On February 21, 2002, the stipulated decisions were entered
by the Court. Those decisions found Geoffrey liable for a 1996
tax deficiency of $1,695,600 and related penalties totaling
$408,411, together with related interest on both amounts; Peter
was found liable for a 1996 tax deficiency of $1,639,157 and
related penalties totaling $416,562.25, together with related
interest on both amounts.
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Last modified: May 25, 2011