Pursuant to agreement of the parties in this case, it is
ORDERED AND DECIDED: That there are deficiencies in tax and penalties due from the petitioners before application of I.R.C. § 6013(e) as follows:
| Deficiency | Additions to Tax/Penalties | |
| Year | in Tax | I.R.C. § 6662(a) |
| 1989 | $ 32,484.00 | $ 2,352.00 |
| 1990 | 45,449.00 | 3,359.00 |
That there are penalties due from petitioner Norman E. Duquette for the taxable years 1989 and 1990, under the provisions of I.R.C. § 6663, in the amounts of $ 8,068.00 and $ 7,161.00, respectively;
That the following deficiencies in tax and penalties are due from the petitioners, under the provisions of I.R.C. § 6013(e):
Joint Liability
| Deficiency | Additions to Tax/Penalties - I.R.C. §§ | ||
| Year | in Tax | 6662(a) | 6663 |
| 1989 | $ 30,000.00 | -0- | - |
| 1990 | 40,000.00 | -0- | - |
Additional Amount Due*58 from Norman E. Duquette
| Deficiency | Additions to Tax/Penalties - I.R.C. §§ | ||
| Year | in Tax | 6662(a) | 6663 |
| 1989 | $ 2,484.00 | $ 2,352.00 | $ 8,068.00 |
| 1990 | 5,449.00 | 3,359.00 | 7,161.00 |
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 deficiencies and penalties due from the petitioners.
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 deficiencies and penalties (plus statutory interest) until the decision of the Tax Court becomes final.
STUART L. BROWN
Chief Counsel
Internal Revenue Service
Date: February 13, 1998
Date: February 11, 1998
Date: 2/13/98