- 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008