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r. based on lack of knowledge or information and denied the
representation in subparagraph q. without qualification.
On February 23, 2004, this case was called for hearing
during the Court’s Seattle, Washington, trial session. The
parties reported that they believed they had reached a basis for
settlement, and the case was scheduled for recall on March 2,
2004. At the recall, the parties indicated on the record that
they had reached an agreement on the deficiencies but had not
settled the issue of penalties. On March 3, 2004, the parties
reported that the case had been settled and requested until April
19, 2004, to submit a signed decision document. In addition, the
parties agreed that the Court did not have jurisdiction over the
proposed addition to tax under section 6651(a)(3), and petitioner
stated on the record that she did not concede that the penalty
should be imposed.
After issuing an order on April 26, 2004, extending the time
for the parties to submit a signed decision document, we filed
the parties’ signed stipulation of settlement on May 10, 2004.
The stipulation of settlement reflected that the parties had
agreed to a section 6015(c) allocation with respect to
petitioner’s and Mr. Owen’s Federal income tax liabilities as
follows:
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