Don M. Ticinovich - Page 4




                                        - 4 -                                         
                    2.  Sch. E Inc/Loss-Partnership/S-Corp adjustment                 
               of $18,290 for the 2003 year - Respondent concedes in                  
               full.                                                                  
                    3.  Self-employment tax and SE AGI adjustments for                
               the 2002 year - These are computational adjustments and                
               will be imposed on the adjustment to Sch. E Inc/Loss-                  
               Partnership/S-Corp for 2002.                                           
                           *    *    *    *    *    *    *                            
          The stipulation also states that there are no additional issues             
          for trial.4  The stipulation was signed by both petitioner and              
          counsel for respondent.                                                     
               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,              
          the holder of petitioner’s power of attorney, Jackson Behar (Mr.            
          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.                      
               On March 2, 2007, respondent filed the motion for entry of             
          decision.  We ordered petitioner to file a response on or before            
          March 30, 2007.  To date, petitioner has not submitted any                  
          response to the Court.                                                      



               4In the stipulation, petitioner also conceded his liability            
          for an accuracy-related penalty under sec. 6662.                            





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