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On August 5, 2005, respondent issued to petitioners a notice
of determination with respect to the Notice of Intent to Levy and
a second notice of determination with respect to the Notice of
Federal Tax Lien Filing. On August 18, 2005, respondent issued a
notice of final determination denying petitioner’s interest
abatement claims. Petitioners timely filed a petition contesting
each of respondent’s determinations. Petitioners contend that
the period of limitations on assessment had expired before
respondent had assessed petitioners’ 1982-84 tax liabilities.
Petitioners further contend that respondent improperly denied
their interest abatement claims.
This case was scheduled for trial during the trial session
of the Court beginning March 6, 2006, at Oklahoma City, Oklahoma.
On March 6, 2006, the parties filed a Stipulation of Facts
(Stipulation) and a Joint Motion for Leave to Submit Case Under
Rule 122, which motion we granted that same day. The
Stipulation, which was signed by both parties, contains 21 pages
and states that “the parties agree to this Stipulation of Facts”
and “All stipulated facts shall be conclusive.” We established a
posttrial briefing schedule that required the parties to submit
their opening briefs on or before May 5, 2006.
On April 27, 2006, approximately 1 week before opening
briefs were due, we had a conference call with the parties at the
request of respondent’s counsel. During that conference call,
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