Duane E. Hudspath - Page 5

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          section 62253 because of the partnership-level proceeding (i.e.,            
          the TEFRA case at docket No. 7982-00).  The Commissioner specifi-           
          cally reserved in respondent’s motion the right to proceed under            
          sections 6221 through 6233 in order to deal with flowthrough                
          computational adjustments resulting from the respective SCC-FPAA            
          and WIN-FPAA and to issue any affected items notice of defi-                
          ciency.                                                                     
               On April 19, 2002, Mr. Hudspath signed, and on April 24,               
          2002, the Commissioner’s counsel signed, a stipulated decision              
          document and a stipulation (parties’ stipulation) in petitioner’s           
          non-TEFRA case at docket No. 7901-00, which they submitted to the           
          Court.  On April 26, 2002, pursuant to the stipulation of the               
          parties, the Court entered a decision in petitioner’s non-TEFRA             
          case at docket No. 7901-00, which stated, inter alia, that there            
          were overpayments of $716 and $709 for Mr. Hudspath’s taxable               
          years 1996 and 1997, respectively,4 and that he was not liable              
          for either 1996 or 1997 for the accuracy-related penalty under              
          section 6662(a).  The parties’ stipulation in petitioner’s non-             
          TEFRA case at docket No. 7901-00 provided:                                  
                    1.  Petitioner reported certain items on his 1996                 
               and 1997 income tax returns related on his investment                  


               3All section references are to the Internal Revenue Code in            
          effect at all relevant times.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
               4The overpayments were the result of increased deductions              
          for interest expenses paid by Mr. Hudspath on behalf of SCC in              
          1996 and 1997.                                                              




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