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Attached to respondent’s motion for partial summary judgment
is a partial copy of a statutory notice of deficiency dated June
1, 1990, issued to petitioners for the following years and
amounts:
Year Deficiency
1974 $1,551.00
1977 16,718.00
1978 5,567.00
1979 6,706.30
1980 4,166.00
1981 3,994.00
Also attached to respondent’s motion is a copy of a
stipulated decision of this Court, entered February 7, 1994, in
the case of Robert H. Golden and Judith A. Golden, docket No.
18777-90, ordering and deciding that there are deficiencies in
income taxes due from petitioners as follows:
Year Deficiency
1974 $1,551.00
1977 2,218.00
1978 5,567.00
1979 6,706.30
1980 4,166.00
1981 3,994.00
Evidence of the Assessments
Certified copies of Forms 4340, Certificate of Assessments,
Payments, and Other Specified Matters, attached as exhibits to
respondent’s motion, show that the above-stipulated deficiencies
were assessed by the IRS on May 10, 1994. Petitioners were
subsequently notified of their outstanding tax liabilities by
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