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Keil that petitioners could review the settlements with Tan while
Montgomery was away on vacation and that he and petitioners could
then discuss the settlements when he returned in January 2004.
On December 18, 2003, Montgomery left the United States on
his scheduled vacation. After he returned, he signed both the
settlement stipulation and the stipulated decision on January 6,
2004. After he returned to the United States, he did not first
talk to either petitioner or Tan as to the matter. Sommers
signed both of those documents on January 13, 2004, and the
parties filed the settlement stipulation with the Court on
January 14, 2004. The settlement stipulation stated:
It is hereby stipulated that the following
statement shows petitioners* income tax liability for
the taxable year 1993:
Tax Liability, computed without allowance
for net operating loss carryback from
taxable year 1995 to taxable year 1993 $168,045.00
Tax assessed: $64,718.00
Payments (April 15, 1994) $20,500.00
(April 15, 1995) $ 1,751.00
(November 28, 1997) $ 5,000.00
(January 22, 1998) $ 5,000.00
Paid $32,251.00
Not paid $32,467.00
Deficiency, without allowance for net
operating loss carryback $103,327.00
Reduction-in liability due to net
operating loss carryback $86,904.00
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