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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine deficiencies of $862,621 and $1,528,818 in their
Federal income taxes for 1993 and 1994, respectively, and related
additions thereto totaling $389,285 and $688,169, respectively.
On December 10, 2003, the parties filed with the Court a
stipulation of settled issues (first stipulation of settled
issues) that stated the terms of a settlement (first settlement)
of approximately 45 out of 50 issues in the case. Six days
later, respondent lodged with the Court a second stipulation of
settled issues (second stipulation of settled issues) that
repeated the substance of the first stipulation of settled issues
and stated the terms of a settlement (second settlement) of the
five issues which were not previously settled. On January 14,
2004, the parties filed with the Court a settlement stipulation
that showed petitioners’ income tax liability (inclusive of any
addition thereto) for 1993 and 1994, as computed on the basis of
the first settlement and the second settlement (collectively,
settlements). On January 27, 2004, the Court entered a
stipulated decision that reflected the amounts shown in the
settlement stipulation.
On February 27, 2004, petitioners moved the Court to vacate
the stipulated decision and to set aside the related stipulations
of settlement. Petitioners asserted in their motion that their
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Last modified: May 25, 2011