Gray v. Comm'r

Pursuant to agreement of the parties in this case, it is

ORDERED AND DECIDED: That there is a deficiency in tax due from the petitioners before application of I.R.C. § 6015 as follows:

That the following deficiency in tax is due from the petitioners, under the provisions of I.R.C. § 6015:

Additional Amount Due from Thomas G. Gray, Jr.

/s/ Michael B. Thornton

Michael B. Thornton

Judge.

Entered: OCT 29 1999

* * * *

It is hereby stipulated that the Court may enter the foregoing decision in this case.

It is further stipulated that interest will be assessed as provided by law on the deficiency due from the petitioner Thomas G. Gray, Jr.

It is further stipulated that, effective upon the entry of this decision by the Court, petitioners waive the restrictions contained in I.R.C. § 6213(a) prohibiting assessment and collection of the deficiency (plus statutory interest) until the decision of the Tax Court *66 becomes final.

STUART L. BROWN

Chief Counsel

Internal Revenue Service

/s/ Jerry W. Neagle

JERRY W. NEAGLE

Counsel for Petitioner

Tax Court Bar No. NJ0248

S225 Katy Freeway, Suite 350

Houston, Texas 77007

Date: 10-26-99

By: /s/ Susan M. Pinner

SUSAN M. PINNER

Tax Court Bar No. PS0250

B701 South Gessner

Suite 710

Houston, Texas 77074

Telephone: (281) 721-7300

Date: 10-26-99