The opinion
THOMAS G. GRAY, JR. and GINA E. GRAY, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Gray v. Comm'r
Docket No. 12139-98
United States Tax Court
1999 U.S. Tax Ct. LEXIS 65 ;
October 29, 1999 , Filed
*65 STUART L. BROWN, Chief Counsel, Internal Revenue Service.
For Petitioner: JERRY W. NEAGLE, Attorney, Houston, Texas.
SUSAN M. PINNER, Attorney, Houston, Texas.
Michael B. Thornton , Judge.
Michael B. Thornton
DECISION 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:
Year Deficiency
1994 $202,363.00
That the following deficiency in tax is due from the petitioners, under the provisions of I.R.C. § 6015 :
Joint Liability
Year Deficiency
1994 None
Additional Amount Due from Thomas G. Gray, Jr.
Year Deficiency
1994 $202,363.00
/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