- 4 -
2. Sch. E Inc/Loss-Partnership/S-Corp adjustment
of $164,608 for the 2003 year - Respondent concedes in
full.
3. Self-employment tax and SE AGI adjustments
for the 2002 and 2003 years - These are computational
adjustments and will be imposed on the adjustments to
Sch. E Inc/Loss-Partnership/S-Corp.
* * * * * * *
The stipulation also states that there are no additional issues
for trial.4 The stipulation is signed by both petitioner and
counsel for respondent.5
When we received the stipulation, we directed the parties to
submit a stipulated decision to the Court by March 7, 2007. On
January 31, 2007, respondent mailed to petitioner a decision
document reflecting the deficiency and penalty that respondent
maintains results from the stipulation. On February 17, 2007,
petitioner’s power of attorney, Jackson Behar, informed
respondent for the first time that petitioner wanted to utilize
Great American’s 2002 tentative section 179 deduction in
calculating petitioner’s 2002 deficiency.
4Petitioner conceded the tax imposed on qualified plans for
2002 and the accuracy-related penalty under sec. 6662, neither of
which affect our decision in this case.
5Respondent noted that on Feb. 28, 2007, the holder of
petitioner’s power of attorney, Jackson Behar, stated that
petitioner claimed not to have signed anything. However,
respondent was not able to contact petitioner to confirm such
claim, and petitioner has not raised the issue before the Court.
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