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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.
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