UNITED STATES TAX COURT

WALTER C. ANDERSON,

Petitioner, v.
COMMISSlONER OF INTERNAL REVENUE,

Re spondent .

) ) ) ) ) ) ) ) )

Docket No.

20364-07

Judge Gustafson

DECISION

Pursuant to agreement of the parties in the above-entitled case, it is
ORDERED and DECIDED: That the following statement shows the deficiencies in income tax and penalties due from the petitioner for the taxable years 1995 through 1999, inclusive, without taking into consideration the jeopardy assessments made
on May 22, 2007:

Year 1995
1996 1997 1998 1999

Deficiency None
None None $50,022,418 $91,475,355

Penalty - §6663 None
None None $37,516,813 $68,467,528

(Signed) David Gustafson
Judge

Entered:

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SERVED MAR - 7 2011

Docket No.

20364-07

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It is stipulated that the foregoing decision is in accordance with the opinion and orders of the Court on the parties' motions for summary judgment, the order dated June 12, 2009 taking notice of respondent's concession of all tax and penalty issues for 1995, 1996, and 1997, and the prior stipulations of the parties, and that the Court may enter the decision without prejudice to the petitioner's right to contest the correctness of the summary judgment opinion and orders entered herein. It is further stipulated that, effective upon entry of this decision by the Court, petitioner waives the restriction contained in I.R.C. §6213(a) prohibiting collection of the deficiencies and penalties (plus statutory interest) until the decision of the Tax Court has become final.

WILLIAM J. WILKINS

Chief Counsel Internal Revenue Service

By• WALTER C. ANDERSON

A N C. MCDOUGAL

Petitioner #27981
FCI Camp

Special Trial Attorney (Small Business/SelfEmployed)

Federal Correctional Institution
P.O. Box 420

Tax Court Bar No. MJ0560 Main Street Centre
600 East Main Street

Fairton, NJ

08320

Suite 1601
Richmond, VA 23219-2430 Telephone: (804) 916-3942

Date:

Date:

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