Legal Opinion

H Graphics/Access, Ltd. Partnership v. Commissioner

United States Tax Court

Decided June 15, 1992No. Docket No. 4298-88UnpublishedCited by 6 opinions

K, a partner in H Graphics, and R executed a "Settlement Agreement for Partnership Adjustments" (Form 870-P). Sec. 6224(c)(1), I.R.C., provides that a partnership settlement agreement is binding on all parties to the agreement absent fraud, malfeasance, or misrepresentation of fact. Sec. 6224(c)(2), I.R.C., further provides that R must offer consistent settlement terms to any other partner who so requests.

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K, a partner in H Graphics, and R executed a "Settlement Agreement for Partnership Adjustments" (Form 870-P). Sec. 6224(c)(1), I.R.C., provides that a partnership settlement agreement is binding on all parties to the agreement absent fraud, malfeasance, or misrepresentation of fact. Sec. 6224(c)(2), I.R.C., further provides that R must offer consistent settlement terms to any other partner who so requests. After requests by other H Graphics partners for settlement terms consistent with those in K's settlement agreement, R repudiated the settlement with K contending that it had been procured…

1Opinion of the Court

H GRAPHICS/ACCESS, LTD. PARTNERSHIP, NELSON J. SAPP, JR., A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

H Graphics/Access, Ltd. Partnership v. Commissioner

Docket No. 4298-88.

United States Tax Court

T.C. Memo 1992-345; 1992 Tax Ct. Memo LEXIS 367; 63 T.C.M. (CCH) 3148;

June 15, 1992, Filed

An appropriate order will be issued.

K, a partner in H Graphics, and R executed a "Settlement Agreement for Partnership Adjustments" (Form 870-P). Sec. 6224(c)(1), I.R.C., provides that a partnership settlement agreement is binding on all parties to the…

2Cases cited28 opinions

  1. Grogan v. GarnerSupreme Court of the United States · 1991
  2. Herman & MacLean v. HuddlestonSupreme Court of the United States · 1983
  3. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  4. Petzoldt v. CommissionerUnited States Tax Court · 1989
  5. Delahanty v. First Pennsylvania Bank, N.A.Supreme Court of Pennsylvania · 1984

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3Cited by6 opinions

  1. Mark Buchine v. Commissioner of Internal Revenue Service, Karen C. Buchine v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1994
  2. Fennell v. United StatesDistrict Court, D. Colorado · 1993
  3. Toker v. United StatesDistrict Court, S.D. New York · 1997
  4. Buchine v. C.I.R.Court of Appeals for the Fifth Circuit · 1994
  5. Buchine v. C.I.R.Court of Appeals for the Fifth Circuit · 1994

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

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