- 7 - petitioner disagreed with respondent’s computation of petitioner’s deficiency on the basis of the items addressed in the stipulation of settlement on the date respondent filed his motion for entry of decision. Petitioner also argues that respondent misled the Court by filing his motion for entry of decision without disclosing, as required by Rule 50(a), that petitioner disagreed with respondent’s computation of petitioner’s deficiency on the basis of items addressed in the stipulation of settlement. We disagree. Rule 155 is the mechanism whereby the Court is enabled to enter a decision in a case where the dollar amounts of the deficiency, liabilities, and/or overpayment cannot readily be determined. Cloes v. Commissioner, 79 T.C. 933, 935 (1982). In accordance with the computations in respondent’s motion for entry of decision, we entered a decision that there is a deficiency of $3,492 in petitioner’s 2000 Federal income tax and that there is no penalty due from petitioner for the taxable year 2000 under section 6662(a). Petitioner does not show that he disagreed with respondent’s computation of petitioner’s tax liability in accordance with the stipulation of settlement, nor does petitioner allege that there was lack of consent, mistake, or fraud as the basis for his motion to vacate order and decision. Instead, petitioner raises new issues involving possible entitlement to a child tax credit,Page: Previous 1 2 3 4 5 6 7 8 Next
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