Himmelwright v. Commissioner
United States Tax Court
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…
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