Legal Opinion

Himmelwright v. Commissioner

United States Tax Court

Decided March 16, 1988No. Docket No. 33800-84UnpublishedCited by 2 opinions

Petitioner H and respondent entered into an oral agreement, confirmed in writing by petitioner H's counsel, settling all issues pertaining to petitioners' Federal income tax liabilities for the years 1974 through 1977. Approximately 2 months after the parties agreed to the settlement, and after the cancellation of a special trial session, respondent was informed that petitioner sought to offset net operating loss carrybacks from the years 1978 through 1980 against the…

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Petitioner H and respondent entered into an oral agreement, confirmed in writing by petitioner H's counsel, settling all issues pertaining to petitioners' Federal income tax liabilities for the years 1974 through 1977. Approximately 2 months after the parties agreed to the settlement, and after the cancellation of a special trial session, respondent was informed that petitioner sought to offset net operating loss carrybacks from the years 1978 through 1980 against the settlements amounts. Held: Decision will be entered in accordance with the parties' original settlement.

1Opinion of the Court

VICTOR F. AND MARIE HIMMELWRIGHT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Himmelwright v. Commissioner

Docket No. 33800-84.

United States Tax Court

T.C. Memo 1988-114; 1988 Tax Ct. Memo LEXIS 143; 55 T.C.M. (CCH) 403; T.C.M. (RIA) 88114;

March 16, 1988; As Amended April 7, 1988; As amended March 21, 1988

Petitioner H and respondent entered into an oral agreement, confirmed in writing by petitioner H's counsel, settling all issues pertaining to petitioners' Federal income tax liabilities for the years 1974 through 1977. Approximately 2 months after the parties agreed to the…

2Cases cited9 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
  3. Cooper-Jarrett, Inc. v. Central Transport, Inc.Court of Appeals for the Third Circuit · 1984
  4. Estate of Ralph L. Jones, Deceased, Zepha H. Jones v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
  5. Cole v. CommissionerUnited States Tax Court · 1958

4 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Yoo Han & Co. v. CommissionerUnited States Tax Court · 1991
  2. Johnston v. CirCourt of Appeals for the Ninth Circuit · 2006

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