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UNITED STATES TAX COURT

WALTER C. ANDERSON, )
)
Petitioner, )
)
v. ) Docket No. 20364-07
)
COMMISSlONER OF INTERNAL REVENUE, ) Judge Gustafson
)
Re spondent . )

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 Deficiency Penalty - §6663


1995 None None
1996 None None
1997 None None
1998 $50,022,418 $37,516,813
1999 $91,475,355 $68,467,528

(Signed) David Gustafson


Judge

Entered:

* * * * *

SERVED MAR - 7 2011


Docket No. 20364-07 - 2 -

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• A
WALTER C. ANDERSON N C. MCDOUGAL
Petitioner Special Trial Attorney
#27981 (Small Business/Self-
FCI Camp Employed)
Federal Correctional Tax Court Bar No. MJ0560
Institution Main Street Centre
P.O. Box 420 600 East Main Street
Fairton, NJ 08320 Suite 1601
Richmond, VA 23219-2430
Telephone: (804) 916-3942

Date: Date: 2-d'//

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