H Graphics/Access, Ltd. Partnership v. Commissioner
United States Tax Court
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…
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