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and a $17,496.50 addition thereto under section 6651(a)(1).1
This case was set for trial on the Court’s regular session
commencing in Denver, Colorado, on September 11, 2006. On
September 7, 2006, the parties met and reached a basis of
settlement. That settlement was later memorialized in a
September 8, 2006, letter sent from respondent to petitioner and
signed by petitioner and delivered back to respondent. The
letter states that the parties have reached the following
agreement regarding petitioner’s 1997 Federal income tax:
1. Petitioner has $127,000 in Schedule C gross
receipts;
2. Petitioner has $57,000 in Schedule C expenses;
3. Petitioner has $30,000 in rental income;
4. Petitioner’s correct filing status is married
filing separately;
5. Petitioner is entitled to the dependency
exemption for one child;
6. Petitioner is liable for an addition to tax
under section 6651(a)(1);
7. Respondent timely mailed the statutory notice
of deficiency and is not barred by the statute of
limitations from asserting the proposed deficiency.
On September 11, 2006, at the calendar of the referenced
session, respondent’s counsel informed the Court that the parties
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Petitioner
resided in Boulder, Colorado, when his petition was filed with
the Court.
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Last modified: May 25, 2011