- 13 - Court granted this request and again confirmed with Sommers that the parties had resolved all issues arising out of the notice of deficiency issued to petitioners. Respondent at that time also lodged with the Court a signed (by Montgomery and Sommers) copy of the second stipulation of settled issues. The second stipulation of settled issues was generally a copy of the first stipulation of settled issues modified to state the terms of the settlement of the five issues which were listed in the first stipulation of settled issues as then still in dispute. The lodged document stated as to these five issues that (1) for 1993, petitioners could deduct $158,320 of contract labor in excess of the $463,577 referenced in the first stipulation of settled issues (i.e., a total deduction of $621,897), (2) for 1994, Continuum (and thus petitioners) could not deduct any business expenses in excess of the $871,480 referenced in the first stipulation of settled issued, but that Continuum (and thus petitioners) had to realize additional income of $225,411, (3) for 1994, petitioners could not under section 1244 deduct any stock loss as to Quest, (4) for 1993, petitioners were liable for the section 6662(a) accuracy-related penalty, and (5) for 1994, 4(...continued) merely states the amount of petitioners’ tax liability for the relevant years and makes no mention of any specific issue underlying that liability. The parties’ settlement of the issues underlying the settlement stipulation, on the other hand, was set forth in the first stipulation of settled issues and the second stipulation of settled issues.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011