Rhett Rance Smith and Alice Avila Smith - Page 2

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          April 5, 2006, objected, and the parties presented their views in           
          documents, the last of which was filed July 3, 2006.  The                   
          question presented by the parties’ controversy is whether                   
          petitioners and respondent entered into an enforceable agreement            
          to settle any part of this case.                                            
          Background                                                                  
               Respondent’s examination in this case focused upon whether             
          petitioners were entitled to certain contribution deductions that           
          they claimed on their Federal tax return.  In the notice of                 
          deficiency, respondent determined that petitioners were not                 
          entitled to deductions for cash contributions claimed on their              
          2002 joint Federal income tax return.  This case was being                  
          handled in Omaha, Nebraska (Omaha case).  The examination in the            
          Omaha case involved only the substantiation of cash contribution            
          deductions.  Respondent had examined earlier taxable years of               
          petitioners, and in those cases the deductibility of noncash                
          contributions was in controversy.  Respondent’s counsel in the              
          Omaha case was Henry N. Carriger.  At the time of the events we             
          consider here, petitioners’ earlier tax years that had already              
          been petitioned to this Court were scheduled for trial in                   
          Phoenix, Arizona, and were being handled by a different counsel             
          for respondent, Anne W. Durning (Phoenix cases).                            
               On June 28, 2005, petitioners’ petition in the Omaha case              
          was filed, and their representatives thereafter began working               






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