- 9 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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