- 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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