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in that motion that the parties had agreed that there is no
deficiency due from Ms. White for taxable year 2001, and
that respondent conceded the additions to tax determined in
the notice of deficiency. Respondent’s second motion also
stated that the parties had entered into a stipulation of
settled issues that would resolve all issues raised in the
notice of deficiency. Respondent’s second motion stated
that the stipulation of settled issues would be filed,
pursuant to Rule 231(c), at the time the estate’s motion
for litigation costs was filed. Respondent’s second motion
was filed approximately 92 days after the petition was
filed. Respondent never filed an answer in this case.
Shortly thereafter, the Court received the stipulation
of settled issues mentioned in respondent’s second motion.
In that document, the parties agreed that Ms. White was not
required to file an income tax return for taxable year
2001. They also agreed that the income reported by the
payors, who are listed above, had been reported on income
tax returns filed on behalf of the estate. In that
document, respondent again conceded that there is no
deficiency in income tax due from Ms. White for 2001, and
that the additions to tax determined in the notice of
deficiency are not due from Ms. White.
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