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August 29, 2005, respondent issued to petitioner a notice of
deficiency that, among other things, adjusted petitioner’s
distributive share of Great American’s net loss for 2002.
On November 21, 2005, petitioner’s petition for a
redetermination of deficiencies for 2002 and 2003 was filed.
Petitioner alleged that respondent improperly denied auto/truck,
amortization, and bad debt expenses claimed by Great American for
2002 and all other expenses claimed in 2003. The petition did
not raise Great American’s 2002 tentative section 179 deduction
that Great American had carried over to 2003. On December 29,
2005, respondent’s answer was filed. This case was calendered
for trial on February 5, 2007, in Los Angeles, California.
On February 5, 2007, counsel for respondent appeared at the
calendar call, announced that the parties had reached a
settlement, and lodged a copy of a fully executed stipulation of
agreed issues (stipulation). Neither petitioner nor a
representative for petitioner appeared at the calendar call.
As pertinent to the issue before us, the stipulation states
as follows:
The parties agree that the adjustments set forth
in the Notice of Deficiency * * * are settled as
follows:
1. Sch. E Inc/Loss-Partnership/S-Corp adjustment
of $29,264 for the 2002 year - Petitioner concedes
$20,362; respondent concedes $8,902.
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