- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT The parties have filed a stipulation of facts, which, with accompanying exhibits (except for 2-R and 4-J1), is incorporated herein by this reference. Petitioners resided in Atlanta, Georgia, at the time the petition was filed. Petitioners filed a joint Federal income tax return for 1995 (the 1995 return), showing a balance due of $2,478.83. Respondent examined the 1995 return and determined a deficiency in tax of $5,282 (the deficiency). The examination concluded with petitioners signing an Internal Revenue Service (IRS) Form 4549-CG, Income Tax Examination Changes (the Form 4549-CG). The Form 4549-CG recites only computational changes based on reported self-employment income and a reported pension distribution. By signing the Form 4549-CG, petitioners agreed to immediate assessment and collection of the deficiency and interest due to March 1, 1997, and waived their appeal rights with the IRS and their right to contest the deficiency in the Tax Court. 1 Exhibit 2-R was admitted into evidence independent of the stipulation of facts. Exhibit 4-J was objected to by petitioner and not admitted at trial. On brief, respondent states that he no longer relies on Exhibit 4-J; therefore, we shall not receive it into evidence.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011