Legal Opinion

Saigh v. Commissioner

United States Tax Court

Decided April 26, 1956No. Docket Nos. 50637, 50641PublishedCited by 46 opinions

1. Stipulations -- Settlement -- Motion to Withdraw -- Good Grounds. -- The Court will not exercise its discretion by granting the Commissioner's motion to withdraw a settlement stipulation where it appears that the stipulation was entered into freely and fairly after long negotiations and independent investigation by the Internal Revenue Service; where all acts by representatives of the Commissioner of Internal Revenue were properly authorized and their authorization was…

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1. Stipulations -- Settlement -- Motion to Withdraw -- Good Grounds. -- The Court will not exercise its discretion by granting the Commissioner's motion to withdraw a settlement stipulation where it appears that the stipulation was entered into freely and fairly after long negotiations and independent investigation by the Internal Revenue Service; where all acts by representatives of the Commissioner of Internal Revenue were properly authorized and their authorization was not withdrawn prior to filing of the stipulations with the Court; and where the Commissioner claims that inadequate…

1Opinion of the Court

OPINION.

MuRdook, Judge:

A stipulation of the amounts of the tax liabilities in each of the following cases, signed by counsel for the parties, was filed with this Court on February 28,1955:

Petitioner DochetNo.

Fred M. Saigh, Jr- 60637

St. Louis National Baseball Club, Inc- 50638

St. Louis National Baseball Club_ 60639

Victor Saigh_ 60640

Fred M. Saigh, Jr., and Elizabeth Saigh_ 50641

Rochester Red Wing Baseball Club, Inc- 50664

The next step would have been for the Court to enter final decisions based upon the stipulations disposing of each of the cases, but before that was done the Commissioner of…

Also in this document: Concurrence.

2Cases cited3 opinions

  1. Illinois Steel Co. v. WarrasWisconsin Supreme Court · 1909
  2. Robinson v. Oregon City Sand & Gravel Co.Oregon Supreme Court · 1933
  3. United States v. Town of Clarksville, VirginiaCourt of Appeals for the Fourth Circuit · 1955

3Cited by46 opinions

  1. Stamm International Corp. v. CommissionerUnited States Tax Court · 1988
  2. Dorchester Indus. v. Comm'rUnited States Tax Court · 1997
  3. Cole v. CommissionerUnited States Tax Court · 1958
  4. Spector v. CommissionerUnited States Tax Court · 1964
  5. Estate of Oman v. CommissionerUnited States Tax Court · 1987

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