Legal Opinion

Dorchester Indus. v. Comm'r

United States Tax Court

Decided April 29, 1997No. Docket Nos. 20515-93, 20572-93, 27121-93, 23092-94Published

R has moved for entry of decisions based on an agreement with Ps to settle these cases. Two Ps argue that they never agreed to settle these cases and, even if they did, they have repudiated that agreement.

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R has moved for entry of decisions based on an agreement with Ps to settle these cases. Two Ps argue that they never agreed to settle these cases and, even if they did, they have repudiated that agreement. Held: Ps entered into a settlement agreement with R. R's motions for entry of decision will be granted with respect to all dockets (except with regard to W). Cole v. Commissioner, 30 T.C. 665 (1958), affd. 272 F.2d 13 (2d Cir. 1959), will not be followed to the extent that it indicates that a party to a settlement agreement that is not filed as a stipulation may repudiate that agreement up…

1Opinion of the Court

DORCHESTER INDUSTRIES INCORPORATED, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Dorchester Indus. v. Comm'r

Docket Nos. 20515-93, 20572-93, 27121-93, 23092-94

United States Tax Court

108 T.C. 320; 1997 U.S. Tax Ct. LEXIS 16; 108 T.C. No. 16;

April 29, 1997, Filed

R has moved for entry of decisions based on an agreement with Ps to settle these cases. Two Ps argue that they never agreed to settle these cases and, even if they did, they have repudiated that agreement.

Held: Ps entered into a settlement agreement with R. R's motions for entry of decision will be granted with…

Also in this document: Concurrence; Dissent.

2Cases cited18 opinions

  1. Swift & Co. v. United StatesSupreme Court of the United States · 1928
  2. Teodore Dorotee Autera v. Manuel Dudley Robinson, Anthony C. Autera v. Manuel Dudley RobinsonCourt of Appeals for the D.C. Circuit · 1969
  3. Williams v. First Nat. Bank of Pauls ValleySupreme Court of the United States · 1910
  4. Olefins Trading, Inc. v. Han Yang Chem CorporationCourt of Appeals for the Third Circuit · 1993
  5. Stamm International Corp. v. CommissionerUnited States Tax Court · 1988

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