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Petitioners resided in Waterloo, Iowa, at the time they
filed the petition in this case.
Petitioners jointly filed a Federal income tax (tax) return
for their taxable year 1988.
On December 18, 1996, respondent issued to petitioners a
notice of deficiency (notice) with respect to their taxable year
1988. Petitioners filed a petition with the Court with respect
to that notice and commenced the case at docket No. 5586-97. (We
shall refer to the case at docket No. 5586-97 as petitioners’ Tax
Court case.)
On January 9, 2001, the Court entered a decision in peti-
tioners’ Tax Court case (Tax Court decision). That decision
provided in pertinent part:
Pursuant to the opinion of the Court filed March
24, 2000, and incorporating herein the facts recited in
respondent’s computation as the findings of the Court,
it is
ORDERED AND DECIDED: That there is a deficiency in
income tax due from petitioners for the taxable year
1988 in the amount of $55,550;
That there is an addition to tax due from peti-
tioners for the taxable year 1988, under the provisions
of I.R.C. section 6653(a), in the amount of $2,777.50;
and
That there is an addition to tax due from peti-
tioners for the taxable year 1988, under the provisions
of I.R.C. section 6661, in the amount of $13,887.50.
On a date not disclosed by the record, petitioners filed a
notice of appeal with the United States Court of Appeals for the
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