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Deficiency, after allowance for net
operating loss carryback $16,423.00
No net operating loss carryback claim filed.
It is further stipulated that there is a
deficiency in income tax due from petitioners for the
taxable year 1994 in the amount of $238,769.00.
It is further stipulated that there are additions
to tax due from petitioners for the taxable years 1993
and 1994, under the provisions of I.R.C. � 6651(a)(1),
in the amounts of $25,831.75 and $47,869.80,
respectively.
It is further stipulated that there are penalties
due from petitioners for the taxable years 1993 and
1994, under the provisions of I.R.C. � 6662(a), in the
amounts of $20,665.40 and $47,753.80.
It is further stipulated that interest will be
assessed as provided by law on the deficiencies,
penalties, and additions to tax due from petitioners.
On January 27, 2004, the Court entered the stipulated decision.
The stipulated decision reflected the amounts shown in the
settlement stipulation.
On February 4, 2004, Montgomery called Tan on a different
matter. During that conversation, she learned that he had
settled petitioners’ case in full. Tan then notified Ms. Keil
that petitioners’ case had been settled. 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 this action should be taken because
Montgomery was unauthorized to agree to the settlements on their
behalf.
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