- 3 - income tax was determined.3 Petitioners timely petitioned this Court in response to that notice, and in due course, respondent assigned the case to Appeals Officer Jeffery L. Sherrill (Mr. Sherrill) for settlement purposes. On August 1, 2003, after reaching a proposed settlement with Mr. Sherrill as to the 1999 deficiency, petitioners received a letter from respondent’s Appeals Office that stated the proposed settlement was “reflected in the [attached] stipulated-decision document” that ultimately would be submitted to the Court. The letter also stated that “If there is an amount due as a result of this settlement, it would be to your advantage to pay the full amount now.” The letter contains no reference to petitioners’ then-outstanding 1999 tax liability that had been previously assessed based upon the amount of tax reported on their 1999 return. On August 20, 2003, a stipulated decision reflecting a $363 deficiency in petitioners’ 1999 Federal income tax was entered in petitioners’ deficiency case. Following the entry of decision by the Court, petitioners remitted a payment of $363 to respondent with respect to the 1999 deficiency. According to petitioners, Mr. Sherrill led them to believe that their 1999 tax liability would be fully satisfied by this payment. 3 The deficiency resulted from petitioners’ failure to report certain gambling income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011