Thomas J. and Bonnie F. Ratke - Page 3




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          prepared in connection with the case in chief are protected from            
          discovery under the work product doctrine privilege in connection           
          with these motions.                                                         
                                     Background                                       
               When the petition was filed in the instant case, petitioners           
          resided in Glendale, Arizona.                                               
               Petitioners timely filed their 1993 Federal income tax                 
          return.  Petitioners showed a $9,238 tax liability for 1993.  On            
          January 9, 1996, respondent sent to petitioners a notice of                 
          deficiency that determined a $20,710 deficiency (liability of               
          $29,948, minus the $9,238 liability shown on petitioners’ tax               
          return) and a $4,142 penalty under section 6662(a).  On March 29,           
          1996, petitioners sent a petition to the Court (docket No. 5931-            
          96, hereinafter sometimes referred to as the 1996 case) disputing           
          the entire amounts of the deficiency and penalty so determined.             
               Also on March 29, 1996, petitioners sent to respondent a               
          second amended 1993 tax return (Form 1040X, Amended U.S.                    
          Individual Income Tax Return) showing a tax liability of $21,893,           
          and showing that this was $12,655 greater than the liability they           
          had previously reported.  On May 27, 1996, respondent made an               
          additional assessment of the $12,655 shown on this Form 1040X,              
          along with interest, and notified petitioners of this additional            
          assessment.                                                                 








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