- 2 - 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.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011