E. Warren Goss - Page 2

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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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