Ghavami v. Commissioner

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

ORDERED AND DECIDED: That there is no deficiency in income tax due from, nor overpayment due to, the petitioner for the taxable year 1993; and

That there are no penalties due from the petitioner for the taxable year 1993, under the provisions of I.R.C. §§ 6651(a)(1) and 6654.

* * * * *

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

It is further stipulated that, effective upon the entry fo this decision by the Court, petitioner waives the restrictions contained in I.R.C. § 6213(a) prohibiting assessment and collection of the deficiency and penalty (plus statutory ionterest) until the decision of the Tax Court becomes final.

STUART L. BROWN

Chief Counsel

Internal Revenue Service

Date: 6/27/00

Date" 6/26/00